1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On April 7, 2008, the Plaintiff acquired and owned shares of the second floor C of the building 2 in Bupyeong-gu, Seoul Special Metropolitan City (hereinafter “instant real estate 1”) and the fifth floor E-1/2 of the building 5th floor E, and transferred the instant real estate 1 and the instant real estate 2 on March 30, 2017, respectively.

B. On January 31, 2017 and May 31, 2017, the Plaintiff: (a) acquired real estate Nos. 1 and 2 in exchange; and (b) reported transfer income tax on the conversion price of each acquisition value ( KRW 411,514,024 for the instant real estate; KRW 153,269,617 for the instant real estate).

C. Upon examining the above details of the report, the Defendant: (a) confirmed that the Plaintiff was actually acquired through the sale, not through the exchange; and (b) notified the Plaintiff of the corrective imposition of KRW 31,572,580, and KRW 9,753,230, respectively, of the transfer income tax for the year 2016, on November 3, 2017, based on the acquisition value (296,227,90, and KRW 80,000,00 for the instant real estate 1; and (c) the value verified in the sales contract and the copy of the register of the real estate register of the real estate.

(hereinafter “instant disposition”) D.

On May 8, 2018, the Plaintiff filed an objection against the instant disposition and filed an appeal with the Tax Tribunal on May 8, 2018, but was dismissed on August 22, 2018.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, Eul evidence Nos. 1 to 3, 1, 2, the purport of the whole pleadings

2. Whether the disposition is lawful;

A. Despite the fact that the Plaintiff’s acquisition of real estate Nos. 1 and 2 of the instant case was actually exchanged, the instant disposition that the Defendant denied and deemed as a sale was unlawful as it did not recognize the acquisition value as the conversion value.

In other words, the Plaintiff’s acquisition of real estate Nos. 1 and 2 of this case (However, the real estate No. 2 of this case includes the remaining 1/2 shares of G) is “one exchange land not exceeding 2,006 square meters prior to H, Gyeyang-gu, the Plaintiff owned.”

The plaintiff and his spouse.