1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

The first instance court.

The court's explanation of this case is the same as the ground for the judgment of the court of first instance. Thus, this case is cited by Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

[This case’s whole records, including evidence submitted by the plaintiff in the trial, are insufficient to recognize that the plaintiff resided in the location of the land of this case and cultivated directly for not less than three years. It is insufficient to deem that capital gains tax was calculated erroneously, and it is also insufficient to recognize a violation of the principle of trust protection because it is unclear whether the plaintiff made an answer to the public officials belonging to the defendant (such as explanation of the circumstance that the plaintiff made business registration with his domicile in Seoul, etc.) by inquiring about what contents the plaintiff had been reduced or exempted from capital gains tax. The judgment of the court of first instance is just, and the plaintiff’s appeal is dismissed as it is without merit, and it is so decided as per Disposition.