1. The Defendant’s transfer income tax amounting to KRW 24,832,820 (including additional tax) for the Plaintiff on December 1, 2016.

1. Details of the disposition;

A. On November 4, 2005, the Plaintiff completed the registration of ownership transfer for the reason of sale on August 12, 2005 with respect to the Seocho-gu Seoul Metropolitan Government E land and its ground building (hereinafter “instant housing”), each of which was owned by 1/2 shares, and transferred the instant housing to F on February 29, 2016 (hereinafter “instant transfer”). On April 25, 2016, the Plaintiff reported and paid the transfer value to the Defendant KRW 1,900,000,000, acquisition value to the Defendant as KRW 1,100,261,437 (Conversion value) for the transfer income tax to KRW 18,845,316.

B. The Defendant conducted a tax investigation on the transfer of this case from October 10, 2016 to October 29, 2016, and confirmed that B and C reported the transfer value to KRW 850,00,000 at the time of reporting the transfer income tax on the housing of this case. On the premise that the real acquisition value of the housing of this case is KRW 850,000,000, the Plaintiff’s transfer income is determined as property under the premise that the real acquisition value of the housing of this case is KRW 850,000. At the time of reporting the transfer income tax of this case, the Plaintiff calculated necessary expenses as KRW 13,290,000, the Defendant calculated the necessary expenses as KRW 143,60,000 at the time of acquiring the housing of this case. At the time of reporting the transfer income tax of this case, the Defendant determined

On December 1, 2016, the Plaintiff notified the Plaintiff of the correction of capital gains tax of KRW 24,832,820 (including additional tax) accrued in 2016.

(hereinafter “instant disposition”). C.

On January 10, 2017, the Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal. However, the Tax Tribunal dismissed the Plaintiff’s appeal on April 19, 2017.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 16 and 17 each 1, 2, Eul evidence Nos. 3 and 5, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. On July 16, 2005, the Plaintiff agreed to purchase the instant house from B and C in KRW 1,090,000,000. The Plaintiff demanded the preparation of a transport contract from B and C and the purchase price of the instant house is KRW 850,00,000.