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 May 12, 2004, the Plaintiff acquired the instant land B 4,618 square meters (hereinafter “instant land”) and transferred it on August 25, 2016, and reported the transfer income tax by applying Article 69 of the Restriction of Special Taxation Act (amended by Act No. 14390, Dec. 20, 2016; hereinafter the same) to “the reduction or exemption for self-farmland for at least eight years.”

B. On July 1, 2017, the Defendant issued a revised notice of KRW 298,661,930 (including additional taxes) for the reason that “the Plaintiff cannot be deemed to have directly cultivated the instant land” to the Plaintiff.

hereinafter referred to as "disposition of this case"

(c) The Plaintiff appealed and filed an objection on September 27, 2017, and filed an appeal with the Tax Tribunal on January 17, 2018, but a ruling dismissing the Plaintiff’s claim was rendered on April 16, 2018. [The Plaintiff did not have any dispute over the grounds for recognition, the entries in Eul’s evidence 1 through 6, and the purport of the entire pleadings.]

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion was unlawful as to the instant disposition, which was made by mistake of facts that the Plaintiff did not own the land even though the Plaintiff cultivated the instant land for not less than eight years.

B. (1) Determination (1) Article 69(1) of the Restriction of Special Taxation Act provides, “The tax amount equivalent to 100/100 of capital gains tax shall be reduced or exempted on the income accruing from the transfer of land prescribed by Presidential Decree, among the land cultivated directly by a resident prescribed by Presidential Decree who resides in the seat of farmland for at least eight years by the method prescribed by Presidential Decree.” Article 66(13) of the Enforcement Decree of the same Act (amended by Presidential Decree No. 27848, Feb. 7, 2017) provides, “The direct cultivation by the method prescribed by Presidential Decree” referred to in the main sentence of Article 69(1) of the Act means that a resident is engaged in cultivating or cultivating crops or perennial plants on his/her own farmland at all times or with his/her own labor.”