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 December 15, 2004 and February 23, 2005, the Plaintiff: (a) transferred the land of this case to 58,413 square meters of B forest land (hereinafter “instant land”); and (b) paid KRW 25,174,766 of the transfer income tax on January 5, 2005 and March 8, 2005, with the transfer value of KRW 570,000,000 (actual transaction value); (c) acquisition value of KRW 420,573,60 (Conversion value); and (d) paid KRW 25,174,766 of the transfer income tax on a preliminary return.

B. The Defendant issued an on-site investigation with respect to the Plaintiff, and subsequently corrected and notified the Plaintiff of the transfer income tax of KRW 291,328,280 (including penalty tax of KRW 17,104,617, and penalty tax of KRW 128,352,255), which reverts to the Plaintiff in July 1, 2013, if the Plaintiff under-reported the transfer income tax by creating a false contract different from the fact, notwithstanding the fact that the transfer value of the instant land was KRW 1 billion.

【Ground of recognition】 The fact that there has been no dispute, entry in the evidence Nos. 2-1, 2-2, and 5, and the purport of the whole pleadings

2. The gist of the Plaintiff’s assertion was that at the time of the transfer of the instant land, the Plaintiff delegated C with a report of capital gains tax, and C believed that it was lawful to report and paid capital gains tax as reported by C.

As such, since the Plaintiff was not involved in the preparation of a false contract on the land of this case and did not evade national taxes due to fraud or other unlawful act, the exclusion period for imposition of the transfer income tax on the land of this case cannot be deemed to have been extended. Accordingly, the disposition of this case is null and void after the exclusion period for imposition of transfer income tax expires

Even if it is not so, the Plaintiff prepared a written contract to transfer the original land in KRW 1 billion, but the Plaintiff agreed to such reduction and received only KRW 800 million by allowing C to cancel the contract without reducing the purchase-price in KRW 800 million after receiving the intermediate payment. Thus, the transfer value of the land in this case is KRW 80 million, even though it is KRW 1 billion.