1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. B is the owner of 12,592/34,404 shares of C, forest land, 34,404 square meters (hereinafter “instant land”) in Sungsung-si, and is the owner of 12,592/34,404 shares, and the joint business chain D (hereinafter “instant business”) was established with other co-owners for the purpose of building and selling the instant real estate on the instant land along with the other co-owners. On December 28, 2006, the instant business invested their shares in kind among the instant land.

B. B calculated the transfer value of its share invested in kind as KRW 1,904,50,000 per square year after reporting the value of the instant land as KRW 500,000, and paid the Defendant the transfer income tax of KRW 295,188,570 on February 28, 2007.

C. B died on January 28, 2009, the Plaintiff solely succeeded to the instant business shares in B. D.

As a result of the personal integration investigation on the instant project from March 2013 to June 2013, the head of the tax office having jurisdiction over the assessment of the acquisition value of the instant land should revise the acquisition value of the instant land by applying the officially assessed individual land price of KRW 53,500/m2 (177,000 per square meter), while the initial joint business operators invested the instant land in kind and calculated the acquisition value of the instant land at KRW 500,000 per square meter (177,000 per square meter). On July 16, 2013, the head of the tax office notified the correction of the comprehensive income tax for other joint business operators except the Plaintiff by excluding the difference between the acquisition value initially reported and the acquisition value corrected as necessary

E. On August 26, 2013, the Plaintiff filed an application for rectification of transfer income tax (hereinafter “instant application for rectification”) stating that the transfer value of the Plaintiff’s share in the instant land that was invested in kind to the Defendant is calculated based on KRW 53,50,00,00,000,000,000 for the said individual land price, and that the amount of transfer income tax paid by B, 29,58,573,000,000,000,0000 won, excluding the amount of claim for rectification calculated as above 95,608,08,087,000,000 won, and the Defendant requested refund of the remaining KRW 19,580,000,000,000,000