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 19, 192, the Plaintiff’s father (the Plaintiff’s father of October 8, 1998) acquired the instant land by means of public sale on March 19, 1992 and on March 26, 1992, the Plaintiff acquired the instant land to H on the grounds of the public sale on August 13, 2014, after acquiring the instant land by inheritance.

B. On October 31, 2014, the Plaintiff directly cultivated the instant land to the Defendant for at least eight years, by applying the special deduction for long-term possession under Article 95 of the former Income Tax Act (amended by Act No. 12852, Dec. 23, 2014; hereinafter the same shall apply) and the reduction or exemption of capital gains tax under Article 69 of the former Restriction of Special Taxation Act (amended by Act No. 13560, Dec. 15, 2015; hereinafter the same shall apply) to the reduction or exemption of capital gains tax under Article 95 of the former Income Tax Act.

C. After conducting an investigation of capital gains tax against the Plaintiff on May 2016, the Defendant determined that the instant land is incorporated into a residential area on January 14, 2004, and it is difficult to view it as being subject to capital gains tax reduction or exemption under Article 69 of the former Restriction of Special Taxation Act, and that it is excluded from the special long-term holding deduction under Article 95 of the former Income Tax Act because it falls under a non-business land, and notified the Plaintiff of the pre-announcement of capital gains tax of KRW 2

On June 22, 2016, the Plaintiff filed a request for pre-assessment review with the Defendant, and the Defendant, in accordance with the re-assessment decision as of August 9, 2016, conducted a re-investigation from August 25, 2016 to September 7, 2016, and determined that the initial disposition was lawful.

Accordingly, on September 13, 2016, the Defendant imposed capital gains tax of KRW 221,228,210 on the Plaintiff in 2014.

E. After November 30, 2016, the Defendant: (a) as the instant land was incorporated into a residential area on January 14, 2004 with respect to the Plaintiff on November 30, 2016, the Defendant issued a notice of reduction of capital gains tax of KRW 182,971 as to the income accrued until January 14, 2004.

I would like to say that a disposition remaining after a reduction or correction is made.