1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The court's explanation of this case is identical to the reasoning of the judgment of the court of first instance, except for dismissal or addition as follows. Thus, it is acceptable to accept this as it is in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. The height of the judgment of the court of first instance is as follows from 2 pages 16 to 20.

“E. After that, the Plaintiff is the former Income Tax Act (amended by Act No. 14389, Dec. 20, 2016; hereinafter “former Income Tax Act”) for the following reasons by the Defendant.

(1) On June 30, 2016, after hearing an explanation that the instant land constitutes “non-business land” under Article 104-3(1)1(a), the report was withdrawn on May 2016, and on June 30, 2016, on the premise that the instant land falls under “non-business land”, the Plaintiff reported KRW 513,16,367 of the capital gains tax on the instant land by applying an aggravated tax rate pursuant to Article 104(1)8 of the former Income Tax Act. 3rd, 18, and 19 of the judgment of the first instance.

On July 26, 2016, the Plaintiff filed a claim for correction with the Defendant to the effect that the instant land does not constitute non-business land, thereby reducing the capital gains tax of the instant land to KRW 513,166,367 to KRW 275,445,528, but the Defendant notified the Defendant of his refusal of the claim for correction on September 20, 2016 (hereinafter “instant disposition”).

(g) The Plaintiff filed an appeal on January 16, 2017 with the content of seeking the revocation of the instant disposition, which was dismissed on April 24, 2017.

3. Additional determination

A. The latter part of Article 168-8(2) of the former Enforcement Decree of the Income Tax Act (hereinafter “instant amendment provision”) stipulates that farmland for which the period of self-defense had already been satisfied prior to its enforcement can be determined differently, without any transitional provision or deferment provision, is enforced in land for non-business use.