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 October 29, 2002, Yongsan-gu Seoul Metropolitan Government B large 257.5 square meters (hereinafter “instant land”) and a single-story house on its ground (hereinafter “instant house”) were registered for the transfer of ownership under C’s name. On September 12, 2002, D ownership was registered for sale on September 12, 2002.

The instant house was removed on December 23, 2003, and thereafter, on the instant land, the building of 2nd floor above the 3rd floor above the 6th floor above the ground (hereinafter “instant building”) was newly constructed, and registration of ownership preservation was made in the name of D on December 31, 2003.

B. Since then, the instant land and the instant building were sold to the Private Teaching Institutes of the School Foundation, and the ownership transfer registration was made on July 5, 2007 due to sale on June 20, 2007.

C. Around December 1, 2009, the Defendant notified D of KRW 367,163,370 of the transfer income tax on the instant land and building, but D did not pay the said transfer income tax.

The Defendant notified the Plaintiff of the gift tax assessment data (D’s donation of KRW 540 million to the Plaintiff) regarding the Plaintiff of the Seoul Regional Tax Office on November 20, 2012, and notified the Plaintiff of the imposition of gift tax of KRW 177,272,550.

E. Around December 27, 2012, the Plaintiff filed a request for pre-assessment review against the notification, and the Defendant, following the National Tax Examination Committee’s review on February 8, 2013, made a decision on re-assessment to the effect that “Inasmuch as it is unclear whether the actual owner of the land or building in this case is D, whether the amount of donation to the Plaintiff is a donation to the Plaintiff should be disposed after clarifying the actual owner of the land or building in this case, and thus, the re-audit should be conducted and the tax base and tax amount shall be corrected according

F. In accordance with the purport of the aforementioned re-audit decision, the Defendant conducted a tax investigation, and deemed the actual owner of the instant land and building as the Plaintiff, and notified the Plaintiff of KRW 517,186,015 of the transfer income tax on March 27, 2013.