1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The purport of the claim and appeal is the purport of the appeal.

1. The reasons why the court accepted the judgment of the court of first instance are the same as the reasons for the judgment of the court of first instance, except for the Plaintiff’s conjunctive assertion that was added to the court of first instance as set forth in the following 2. Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence

2. Judgment as to the conjunctive assertion added by this Court

A. Determination 1 on the assertion that the penalty surcharge should be mitigated) The Plaintiff’s assertion that the instant forest should be mitigated is based on the Act on the Registration of Real Estate under Actual Titleholder’s Name (hereinafter “Real Estate Real Name Act”), even if the Plaintiff trusted the instant forest to C, since the Plaintiff did not have the intent to evade taxes or avoid statutory restrictions

(2) The proviso of Article 3-2 of the Enforcement Decree of the Real Estate Real Name Act provides that a penalty surcharge may be mitigated by 50/100 if the penalty surcharge is not for the purpose of evading taxes or avoiding restrictions under the laws and regulations. The assertion that the penalty surcharge is not for such purpose must be mitigated pursuant to Article 5(3) and the proviso of Article 3-2 of the Enforcement Decree of the same Act.

(3) In the instant case, as seen earlier, since the value of the instant forest does not amount to the value of the forest, and the period of title trust was considerably long, the Plaintiff appears to have avoided a considerable amount of taxes by title trust on the instant forest. In light of the fact that the reason behind title trust on the instant forest is unclear and it is difficult to find any statutory restrictions that are not possible to register the instant forest under the Plaintiff’s name, the evidence submitted by the Plaintiff alone is insufficient to recognize that the Plaintiff was not with the intention to evade taxes or avoid restrictions under the relevant laws and regulations while title trust on the instant forest. The Plaintiff’s assertion is without merit.

(b)calculated the officially announced value;