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 March 28, 2013, the Plaintiff: (a) transferred farmland of KRW 16,597 square meters (hereinafter “instant farmland”) to KRW 2,129,476,556; (b) calculated the acquisition value as KRW 1,182,456,671; and (c) calculated the calculated tax amount as KRW 209,080,23; and (d) reported and paid KRW 100,000,00 for the farmland of KRW 109,489,280 for the farmland of KRW 2013 pursuant to Article 70 of the Restriction of Special Taxation Act.

B. On February 27, 2014, the Defendant issued a notice by correcting KRW 348,890,430 to the Plaintiff, by excluding the instant farmland from the reduction or exemption of capital gains tax pursuant to farmland substitute land, on the grounds that “the Plaintiff did not reside in the instant farmland for at least three years, and cannot be deemed to have cultivated the instant farmland directly.”

(hereinafter referred to as “instant disposition”). C.

On May 2, 2014, the Plaintiff filed an appeal with the Tax Tribunal on May 2, 2014, but the said claim was dismissed on September 17, 2014.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, Eul evidence Nos. 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. Since acquiring the farmland of this case from around 1980, the Plaintiff had resided in the location of the farmland of this case and cultivated the farmland of this case.

Therefore, since the farmland in this case does not fall under the land for non-business use pursuant to the main sentence of Article 104-3 (1) 1 (a) of the Income Tax Act by satisfying the requirements for re-resident re-resident, the special long

Even if the farmland in this case does not meet the requirements for the re-resident, the farmland in this case satisfies the requirements under the proviso of Article 104-3 (1) 1 (a) of the Income Tax Act and Article 168-8 (3) 7 of the Enforcement Decree of the Income Tax Act, and ultimately does not constitute non-business land, and thus is subject to the special long-term holding deduction. Thus, the disposition in this

B. Entry in the relevant laws and regulations attached thereto.