1. On February 9, 2012, the Defendant imposed capital gains tax of KRW 724,556,210 on the Plaintiff for the year 2007.

1. Basic facts

A. On February 24, 2005, the Plaintiff acquired each land listed in [Attachment 1] Nos. 1 through 6 in [Attachment 1] list (hereinafter “instant land”) and transferred the instant land to B on March 14, 2007.

B. On May 15, 2007, when the Plaintiff filed a final return on the tax base of capital gains tax on the instant land on May 15, 2007, the Plaintiff reported and paid 18,608,770 won of capital gains tax calculated by applying the transfer value as KRW 1,774,00,000, and the acquisition value as KRW 1,650,000.

C. On February 9, 2012, the Defendant issued a revised disposition of capital gains tax for the Plaintiff: (a) on the ground that the Plaintiff submitted a false acquisition contract at the time of filing a final return of tax base of capital gains tax and filed an excessive return; and (b) the Plaintiff did not apply the corresponding heavy taxation rate to the instant land corresponding to non-business land, the Defendant issued a revised notice of increase in capital gains tax for KRW 876,028,355 (including additional tax 179,99,99,999, additional tax 194,135,298, additional tax 197,419,5777) calculated by applying the heavy taxation rate for non-business land.

On April 27, 2012, the Plaintiff was dissatisfied with the above disposition of increase or decrease, and requested a trial to the Tax Tribunal on April 27, 2012. On January 30, 2013, the Tax Tribunal accepted some of the Plaintiff’s necessary expenses, and recognized the transfer value of KRW 1,774,000,000 as capital expenditure of KRW 87,000 and brokerage commission of KRW 80,00,000 as necessary expenses, and accordingly corrected the tax base and tax amount of capital gains tax and the remainder of the request was dismissed.

Accordingly, the defendant against the plaintiff on February 6, 2013, according to the decision of the Tax Tribunal, the above capital expenditure and brokerage commission.