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 reasoning of the court’s explanation concerning this case is as follows: (a) the part of the reasoning of the judgment of the court of first instance is dismissed as provided in paragraph (2); and (b) the Plaintiff’s new argument in the trial of the court of first instance is identical to the entry of the reasoning of the judgment of the court of first instance, except where the judgment on the Plaintiff’s new argument is added as provided in paragraph (3). As such, it is likewise accepted in accordance with Article

2. Parts of the judgment of the first instance; and

A. Article 69(1) of the Restriction of Special Taxation Act provides that a tax amount equivalent to 100/100 of capital gains tax on income accruing from the transfer of land prescribed by Presidential Decree among the land cultivated by a resident prescribed by Presidential Decree who resides in the seat of farmland for at least eight years shall be reduced or exempted, and the Enforcement Decree of the Restriction of Special Taxation Act (Amended by Presidential Decree No. 25211, Feb. 21, 2014; Presidential Decree No. 25211, Feb. 21, 2014; hereinafter “former Enforcement Decree of the Restriction of Special Taxation Act”).

(3) Article 66(13) of the same Act provides that “Direct cultivation by means prescribed by Presidential Decree” means that a resident engages in cultivation of crops or growing perennial plants on his/her own farmland by using “on a commercial basis” or “one-half or more of his/her own labor force” for farming work. Here, the meaning of “on a commercial basis” and “one-half or more own labor force” ought to be interpreted in accordance with the language and text (see, e.g., Supreme Court Decisions 2010Du8423, Sept. 30, 2010; 2012Du19700, Dec. 27, 2012; and a person who is engaged in a part of for reasons, such as having another occupation, not on a regular basis, shall be deemed directly cultivated only when the input ratio of “on a own labor force” excluding the labor force of his/her family members or the mechanization work by others during the entire farming work.