1. Revocation of a judgment of the first instance;

2. The Defendant’s transfer income tax attributed to the Plaintiff on May 20, 2013 576,023.

1. Details of the disposition;

A. On February 3, 1989, the Plaintiff acquired 3,305.4 square meters of forest B 124,595 square meters (hereinafter “instant land”) in Sungnam-si, Sungnam-si, and transferred the same to C Co., Ltd. on September 28, 2007.

B. On November 30, 2007, when the Plaintiff reported and paid the transfer income tax on the instant land, the transfer value is KRW 600,000,000, which is the actual transaction value, and the acquisition value was KRW 597,000,000, which is the conversion value on the ground that the evidential document was destroyed by fire. The Defendant calculated the acquisition value of the instant land by the transaction example amounting to KRW 13,49,254, which is calculated by the amount equivalent to KRW 4,083.7,00,000 per square meter, and issued a disposition to correct and notify the transfer income tax for the year 2007, including the additional tax for the transfer income tax for the year 2007 (hereinafter “instant disposition”).

C. On August 14, 2013, the Plaintiff filed an appeal for adjudication against it, but received a decision of dismissal from the Tax Tribunal on December 4, 2013.

[Reasons for Recognition] Uncontentious Facts, Gap evidence 1 through 4, Gap evidence 12-1, 2, Eul evidence 1, the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion (1) Each sales contract in the name of D and E, which is the basis for transaction example, is merely a so-called approval seal contract prepared in a lump sum for tax convenience.

The purchase price stated in each of the above sales contracts is less than 1/10 of the officially assessed individual land price as of January 1, 1990. The whole land price of this case is an area where the Plaintiff acquired a share in the land of this case, and the sale price of this case was sharply increased during the pre-sale process without registration, and each of the above sales contracts cannot be deemed an actual sales contract, in light of the practice of preparing a seal of approval at the time of this case, etc.

Therefore, the sales price under each of the above sales contracts cannot be considered as a transaction example.

(2) Even if the instant disposition is rendered, the principal amount of capital gains tax is part.