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 May 27, 2005, the Plaintiff acquired the building of 551.9 square meters and its ground building of 1,516.93 square meters (hereinafter collectively referred to as “instant real estate”) from Daejeon Seo-gu Daejeon, Daejeon, Daejeon, and transferred the instant real estate to D on February 22, 2006 (hereinafter referred to as “instant transfer”).

B. After the transfer of the instant case, the Plaintiff reported the transfer income tax by stating the acquisition value of KRW 1 billion as “acquisition value of KRW 40 billion and KRW 1.1 billion in transfer value.”

C. D, the transferee of the instant real estate in 2012, stated the acquisition value as KRW 1.7 billion and reported the transfer income tax. Upon examining the actual transfer value of the instant transfer in 2014, the Defendant confirmed that the transfer value was KRW 1.477 billion (the transfer value at the time of the sales contract was determined as KRW 1.7 billion but the said amount was actually paid only) and subsequently, on August 1, 2014, the Plaintiff issued a corrective notice of KRW 330,181,261 in the transfer income tax corresponding to the year 2006 (i.e., calculated tax amount of KRW 175,097,7450, KRW 13757,574, and KRW 666 (hereinafter “instant corrective notice”).

On October 31, 2014, the Plaintiff filed an appeal against it, and on March 11, 2015, the Tax Tribunal dismissed it.

[Ground of recognition] Facts without dispute, Gap evidence 1, Eul evidence Nos. 1, Eul evidence Nos. 1, 2 and 3 (including paper numbers), the purport of the whole pleadings

2. The plaintiff's assertion

A. A taxpayer of capital gains tax following the transfer of this case is a title truster D (the Plaintiff’s wife, E).

The Plaintiff only lent the name following the acquisition of the instant real estate to D in accordance with the title trust agreement with D, and there is no income from the transfer of the instant real estate.

B. The acquisition value of the instant real estate is KRW 1.6 billion in total, including the purchase price of KRW 1.5 billion and the remodeling cost of KRW 1.6 billion.

In other words, the seller B is the seller at the time.