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 June 30, 2003, the Plaintiff acquired the building from Gangnam-gu Seoul Metropolitan Government C large-214.2 square meters (hereinafter “instant land”) and the building on its ground, and constructed five-story buildings of neighborhood living facilities (hereinafter “instant building”) after removing the building, and obtained approval for use on December 31, 2004.

B. On December 30, 201, the Plaintiff transferred the instant land and buildings to D in KRW 4,850,000,000.

C. The Plaintiff calculated the acquisition value of the instant land and the instant building as KRW 2,796,964,770 (land 1,879,841,834, building 917,122,936), and reported and paid KRW 526,135,170, capital gains tax. However, on May 1, 2013, the Defendant issued a revised and notified the Plaintiff on May 1, 2013 on the ground that the actual acquisition value of the instant land was confirmed respectively as KRW 1,080,00,000, and the actual acquisition value of the instant building was confirmed as KRW 486,863,240, capital gains tax for the year 2011.

(hereinafter “instant disposition”) D.

The plaintiff was under the procedure of the previous trial.

[Grounds for Recognition] Unsatisfy, Gap 1 to 4-2, Eul 1 to 3

2. Whether the instant disposition is lawful

A. In addition to the construction cost paid to the Hans Industry Development Co., Ltd. for the construction of the instant building alleged by the Plaintiff, the Plaintiff additionally paid the construction cost up to several hundred million won by performing artificial insemination, etc., but it is difficult for the Plaintiff to pay the construction cost by cash or deposit without passbook and to disclose the amount thereof. Thus, the acquisition price of the instant building should be calculated by conversion price.

Therefore, the instant disposition taken on a different premise is unlawful.

B. The burden of proof on the tax base, which is the basis of taxation, is the tax authority in a lawsuit seeking revocation of the income tax disposition, and the tax base is the tax authority's burden of proof on revenue and necessary expenses, as the tax base deducts necessary

or necessary expenses shall not be required.