1. The Defendant’s disposition of imposing capital gains tax of KRW 202,946,200 against the Plaintiff on December 5, 2016 shall be revoked.

2...

1. Details of the disposition;

A. On May 31, 2007, the Plaintiff: (a) on July 31, 2007, registered the subdivision of the area of 4,313 square meters and 4,003 square meters prior to E on July 17, 2008; (b) on September 28, 2016, the Plaintiff was re-merged on September 28, 2016.

After registration conversion on July 17, 2008 with Q forest 6,939 square meters on Q forest 6,960 square meters prior to registration conversion, registration was made by dividing Q forest 1,752 square meters, R forest 4,587 square meters, S forest 223 square meters, and T forest 398 square meters on September 28, 2016, and registration was made by dividing Q forest 6,339 square meters.

G acquisition of a forest land of KRW 476 square meters, H forest land of KRW 890 square meters, and 163 square meters of I forest land of KRW 163 square meters (hereinafter “instant land”), regardless of whether before or after the division or merger, and completed the registration of ownership transfer in the name of the Plaintiff on June 7, 2007.

B. On October 28, 2014, the Plaintiff agreed to exchange the instant land with the 406 square meters in Seo-gu, Seodong-gu, Cheongju-si and with the 801.81 square meters in detached houses and neighborhood living facilities, and 801.81 square meters in MM (hereinafter collectively referred to as “N real estate”). The Plaintiff’s exchange contract with the purport that the instant land shall be assessed as KRW 220 million, N real estate as KRW 820 million, and that the Plaintiff shall additionally pay KRW 80 million (Evidence 6) is not indicated as the exchange goods, but appears to be erroneous.

(hereinafter “instant exchange contract”) is concluded, and on October 28, 2014, the registration of ownership transfer was completed on October 22, 2014 by J as to N real estate.

C. On September 3, 2015, the Plaintiff prepared a sales contract (Evidence A) dated September 3, 2015, stating that K and the Plaintiff entrusted with the power to dispose of the instant land by J sell the said land to K in KRW 220 million, and completed the registration of ownership transfer on October 8, 2015 with respect to the said land on September 3, 2015.

Meanwhile, K on October 7, 2015, purchase price of the instant land with O on October 7, 2015.