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 November 14, 1984, the Plaintiff acquired the 1,323 square meters of the rice field B (hereinafter “instant land”) in Yong-Gun, Chungcheongnam-do (Seoul-do) (hereinafter “instant land”), but transferred KRW 527,000,000 to C on September 6, 2016.

B. On October 31, 2016, the Plaintiff reported capital gains tax by applying the special deduction for long-term holding under Article 95(1) of the Income Tax Act and the reduction or exemption of self-arable farmland under Article 69 of the Restriction of Special Taxation Act to the instant land.

C. The Plaintiff’s total wage of earned income is as follows:

The gross pay for the year 1995 22,652,760 202 46,776,770 209 29,589,589,000 47,969,969,969,880 41,694, 260 32,092,092,92,652,760 41,407,407, 208 41,407, 207, 407, 404, 207, 207, 208, 197, 207, 304, 207, 207, 404, 506, 870, 1998, 306, 4306, 1964, 208, 207, 31964, 1968

D. After investigating the transfer income tax on the instant land, the Defendant: (a) exempted the application of the special long-term holding deduction under Article 95(1) of the former Income Tax Act (amended by Act No. 14389, Dec. 20, 2016; hereinafter the same) on June 1, 2018, on the ground that the Plaintiff’s annual total salary exceeds 37 million won and exceeds 40%, and the instant land constitutes non-business land pursuant to Article 66(14) of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 27848, Feb. 7, 2017; hereinafter the same shall apply) (hereinafter “instant disposition”).

E. The Plaintiff dissatisfied with the instant disposition and filed a tax appeal on September 4, 2018, but was dismissed on December 4, 2018.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 4, 5, Eul evidence Nos. 1 to 3, and all pleadings.