1. Disposition of imposition of capital gains tax of KRW 103,817,840 for the Plaintiff on November 1, 2014, and disposition of KRW 103,817,840 for the Plaintiff on November 1, 2006.

Details of the disposition

On January 31, 1981, the Plaintiff completed the registration of initial ownership relating to B large 11,680 square meters (hereinafter “instant land before subdivision”). The land before subdivision was divided into a number of land including each land listed in the separate sheet from July 2002 to December 2005.

As of the date indicated in the “transfer date” column of the attached list 1, the Plaintiff transferred each “land” column of the same list (hereinafter “each land of this case”) to the transferee indicated in the “transferee” column of the same list (hereinafter “the respective transfer transaction of this case”). The Defendant reported and paid the transfer income tax on each transfer transaction of the above land as the respective amount indicated in the “transfer value of Plaintiff Report” column of the same list (hereinafter “transfer value of Plaintiff Report”).

From April 14, 2014 to May 18, 2014, the Defendant investigated the actual transaction value of each of the instant lands and determined that the actual transaction value of each of the instant transfer transactions is the amount indicated in the “transfer value” column in the attached Table 1 list (hereinafter “Defendant confirmation transfer value”). On November 7, 2014, the Defendant issued a correction notice of capital gains tax (including additional tax) stating that the Plaintiff shall additionally pay capital gains tax of KRW 103,817,840 (including additional tax) and capital gains tax of KRW 48,043,220 (including additional tax) reverted to the year 206.

On December 15, 2014, the Plaintiff filed an objection seeking the revocation of the instant disposition with the Defendant, but the Defendant dismissed all the said objection on January 7, 2015. The Plaintiff filed an appeal on February 16, 2015, but the Tax Tribunal dismissed all the Plaintiff’s claim on June 22, 2015.

[Ground of recognition] A without any dispute, Gap evidence 9-1, 2, 10, 12, 13, Eul evidence 1-1, 2, 2-2, and Eul evidence 1-2, the purport of the whole pleadings, and the plaintiff's assertion as to the purport of the whole pleadings, and the judgment of plaintiff 1 and C.