1. The Defendant’s transfer income tax (including additional tax) for the year 2003 owed to the Plaintiff on May 1, 2013 is KRW 70,759,400.

1. Details of the disposition;

A. The Plaintiff acquired the instant real estate from C on September 3, 2002 and transferred D KRW 6.40 million to D on July 23, 2003, by combining land and buildings (hereinafter referred to as “instant real estate”).

B. On August 12, 2003, the Plaintiff made a preliminary return of the transfer value of the instant real estate as KRW 5.1 million with the acquisition value as KRW 5.1 million, and the transfer value as KRW 500 million with the acquisition value as KRW 500 million.

C. After D transferred the instant real estate in 2007, it reported the acquisition value of the instant real estate as KRW 6,40,000,000,000, the director of the tax office having jurisdiction over the transfer value of the instant real estate on September 24, 2009, after a tax investigation in 2009, determined the Plaintiff’s transfer value as KRW 6,40,000,000,000, and notified the Defendant and the director of the tax office of the tax base of the results.

On April 6, 2011, the head of the Geumcheon Tax Office notified C of the transfer value of the instant real estate as KRW 600 million.

C On May 6, 2011, the head of the Geumcheon Tax Office filed a request for pre-assessment review on the grounds that C’s transfer value of the instant real estate was KRW 500 million, and on May 26, 201, the head of the Geumcheon Tax Office decided to adopt the instant real estate transfer value on the grounds that C’s transfer value of the instant real estate was KRW 500 million.

E. On March 15, 2013, the Defendant notified the Plaintiff of the acquisition value of the instant real estate as KRW 500 million and notified the Plaintiff of the pre-announcement of taxation.

On March 28, 2013, the Plaintiff filed a request for pre-assessment review with the Defendant on the ground that the Plaintiff’s acquisition price of the instant real estate was KRW 600 million, and the Defendant rendered a non-adopted decision on April 29, 2013.

F. On May 1, 2013, the Defendant imposed upon the Plaintiff a disposition of imposition of KRW 70,759,400 for capital gains tax (including additional tax; hereinafter the same shall apply) for the year 2003 on the Plaintiff’s acquisition value of the instant real estate as KRW 500 million (hereinafter “instant disposition”).

G. The Plaintiff filed a tax appeal, and the Tax Tribunal rendered a request on December 18, 2013.