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 September 10, 2002, the Plaintiff purchased a building of three floors above the ground level 455.1 square meters and three floors above the ground level located in the Busan Northern-gu, Busan (hereinafter “instant bath”) from B, and completed the registration of ownership transfer on October 25, 2002. On August 28, 2012, the Plaintiff completed the registration of ownership transfer on May 31, 2012 to D for sale.

B. On October 31, 2012, the Plaintiff reported the transfer income tax for the taxable year 2012 with the acquisition value of KRW 1,455,00,000 and the transfer value of KRW 1,480,000,000.

C. Since then, the Defendant: (a) deemed the acquisition value as KRW 1,430,00,00 based on the newly presented contract, and notified the Plaintiff of the correction and notification of the transfer income tax for the year 2012; (b) on October 13, 2014, the Plaintiff issued a correction and notification of the acquisition value as KRW 1,249,936,717, the conversion price for the reason that the acquisition value is unclear; and (c) on October 13, 2014, the Plaintiff issued a correction and notification of the transfer income tax

(hereinafter “instant disposition”) D.

The Plaintiff filed a tax appeal through the filing of an objection, but was dismissed on May 12, 2015.

[Ground of recognition] Facts without dispute, Gap evidence 3, 4, Gap evidence 7-2, Gap evidence 8, 9, Eul evidence 1 through 5, and the purport of the whole pleadings.

2. Determination on the lawfulness of the instant disposition

A. The Plaintiff’s assertion D exchanged real estate equivalent to KRW 1,058,00,000 on the instant bath and D’s market price of KRW 180,000 on the condition that D’s secured loan amounting to KRW 990,00,00,000, total of KRW 50,000,000, such as the Energy Utilization Rationalization Fund, and the refund claim of deposit for lease deposit, etc., and eventually, the transfer value of the instant bath and D’s bath is KRW 1,238,00,000,00.

In addition, the Plaintiff acquired the bath of this case in KRW 1,430,000,00 and calculated the acquisition value at the conversion price on the ground that the actual transaction price exists.

As such, the Defendant’s transfer value and acquisition value.