The plaintiff's appeal is dismissed.

Expenses for appeal shall be borne by the plaintiff.

The purport of the claim and the purport of the appeal are the judgment of the first instance.

1. Details of the disposition;

A. On January 11, 2016, the Plaintiff: (a) transferred the Songpa-gu Seoul Metropolitan Government Building E (hereinafter “transfer house”) through a voluntary auction while holding the Gangdong-gu Seoul Metropolitan Building C (hereinafter “instant house”); (b) but (c) did not file a return on the transfer income tax.

B. On November 1, 2018, the Defendant deemed that the Plaintiff owned two houses at the time of the transfer of the said house, and notified KRW 254,923,050 of the transfer income tax for the year 2016 following the transfer of the house for transfer. The Plaintiff was served with the notice of the transfer income tax on November 22, 2018 (hereinafter “instant disposition”).

The Plaintiff filed the instant lawsuit on March 26, 2020. After the judgment of the first instance was rendered, the Plaintiff filed an appeal with the Tax Tribunal on July 30, 2020 on the instant disposition. However, the Tax Tribunal dismissed the Plaintiff’s appeal on the ground that the said appeal was filed on November 19, 2020 with the lapse of the period for requesting the above appeal and was in an incidental law.

(d)

On November 29, 2011, the F Apartment Housing Reconstruction Improvement Project Association (hereinafter referred to as the “Union”) filed a lawsuit against the Plaintiff for claiming the sale of housing at issue (hereinafter referred to as “instant claim for sale”), and received payment of KRW 231,00,000 from the Cooperative, the Plaintiff was sentenced to a favorable judgment of the Plaintiff on March 15, 201 (Seoul District Court Decision 201No. 3747), and the Plaintiff (the Defendant of the instant case) filed an appeal on September 28, 2012, and the said judgment became final and conclusive around that time (Seoul High Court Decision 201Na6082).

A union deposited KRW 231,00,000 as the Seoul Eastern District Court No. 2528 on July 5, 2017 in accordance with the said final judgment, and thereafter, deposited KRW 231,00,000 as the purchase price of the real estate in this case, based on the Seoul Eastern District Court’s receipt on July 26, 2017, as Seoul Eastern District Court’s 113075 on the issue of the housing, on March 15, 2011.