1. Revocation of a judgment of the first instance;

2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. The deceased H (hereinafter “the deceased”) is the husband of the Plaintiff, and G is the Plaintiff’s starting machine.

B. As to the parcels (C, D, E, F, and hereinafter “each of the instant lands”) outside Jeonnam-gun, Jeonnam-gun, and four parcels (hereinafter “each of the instant lands”), registration has been completed as follows:

The lot number owner/acquisition date / The deceased on June 8, 2007, who was donated on July 10, 2007, the deceased on July 10, 2007, and on July 30, 2009, the deceased on July 10, 2009, as the donation I, on April 16, 2010, J CK on June 8, 2010 (former L), on June 24, 2010, sale DG on June 24, 2010, and sale EF on June 21, 2094, donated on May 11, 2006 by the deceased on June 23, 2010.

C. On January 2, 2015, the Defendant imposed a gift tax of KRW 43,388,430 on each of the instant land (donations 184,502,260) on April 16, 2010, on G, on the ground that G did not pay the gift tax and it was difficult for G to secure a tax claim due to lack of ability to pay the delinquent tax, and on the same day, G designated the Plaintiff as a joint and several taxpayer and notified the Plaintiff of the payment of the gift tax.

The Plaintiff filed an objection with the Defendant on March 24, 2015, but was dismissed on April 22, 2015, and filed a request for examination with the Commissioner of the National Tax Service on May 20, 2015, but was dismissed on June 24, 2015.

E. On the other hand, the Defendant, on April 1, 2015, deemed the gift tax amount of KRW 141,902,260 (=184,502,260-42,600,000) as the gift tax amount of KRW 29,277,370 on the grounds that the value of each of the instant land in the instant case was corrected not to be KRW 102,60,000 but to be KRW 60,000, not to mention the value of each of the instant land in order to reduce the said gift tax to KRW 29,27,370.

(hereinafter referred to as the above, the disposition imposing the gift tax that has been reduced or corrected as above is "the disposition of this case"). [Grounds for recognition] The fact that there is no dispute, Gap evidence Nos. 1 through 4, Eul evidence Nos. 1 through 7 (including each number if there is a provisional number) and the purport of the whole pleadings.

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion 1 G: (a) donated each of the instant lands to the Deceased; (b) terminated the donation contract after the Deceased’s death; and (c) terminated the said land.