1. The plaintiff's claim is dismissed.

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

1. (i) On November 22, 2000, the Plaintiff acquired the instant land and its neighboring farmland (referring to D, E, and F land) by adding up two parcels of land B, B, 578 square meters prior to C, and 7 square meters prior to C (hereinafter the above two parcels of land) and transferred all the farmland in the said five parcels of land on April 10, 2014.

B. On March 21, 2001, on which the farmland of the said five parcels is located, the Luxembourg-gun was changed to the Si in the complex form of urban and rural communities, and the said five parcels were changed to the “Sesung-si Gdong.” Of the farmland of the said five parcels, the two parcels of the instant parcels of land were included in the Class I general residential area on September 4, 2006.

On June 27, 2014, the Plaintiff made a preliminary return to reduce the full amount of KRW 92,742,510 for the transfer income tax belonging to the year 2014 on the ground that the Defendant satisfies the requirements for the self-sufficiency in eight years with respect to the farmland of the said five parcels.

Applicant "Ssung-si Gdong" was changed on October 20, 2014 to "Seoul-Eup" again on October 20.

(v) On February 12, 2016, the Defendant issued the instant disposition to the Plaintiff, on the ground that the instant controversial land, which was farmland in the city of urban and rural complex form, was transferred on April 10, 2014, and was not subject to capital gains tax reduction or exemption on the ground that it was transferred on September 10, 2014, on the ground that the instant land, which was farmland in the city of urban and rural complex form, was not subject to capital gains tax reduction or exemption (=calculated tax amounting to KRW 92,742,517), KRW 61,810,646, and KRW 5,493,50, and KRW 5,500, and KRW 61,810,646, and KRW 5,493,500) was corrected and imposed on the Plaintiff.

The Plaintiff, who was dissatisfied with the instant disposition, filed an appeal with the Tax Tribunal on October 27, 2016, but the appeal was dismissed on October 27, 2016.

[Judgment of the court below] Facts without dispute, Eul evidence Nos. 1, 2, 3 and the purport of the whole pleadings

2. According to Article 69(1) of the Restriction of Special Taxation Act and Article 66(4)1 of the Enforcement Decree of the Restriction of Special Taxation Act, the instant disposition is legitimate, and is established under Article 3(4) of the Local Autonomy Act as of the date of transfer.