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 December 19, 2008, B and C transferred to D the land of this case 1,103 square meters prior to Sungnam-si, Sungnam-gu E (hereinafter “instant land”), and then filed a preliminary return of capital gains tax with the head of Sungnam-gu Tax Office. At that time, B and C submitted a sales contract (Evidence No. 7; hereinafter “A contract”) stating that “The land of this case was transferred from F to KRW 1,334,60,000.”

B. On October 201, the head of Seongbuk-Nam District Tax Office: (a) conducted a tax investigation on the instant land; (b) deemed that B and C acquired the instant land from the Plaintiff in KRW 1,000,000; and (c) notified B and C of the rectification of capital gains tax.

C. Accordingly, B filed an objection with the head of Sungnam District Tax Office by submitting a sales contract (No. 14 certificate; hereinafter “B”) stating that “B and C purchase the instant land from the Plaintiff,” and the head of Sungnam District Tax Office ex officio revoked the said disposition of transfer income tax and notified the Defendant thereof.

On the other hand, on November 20, 2013, the Plaintiff filed a sales contract (No. 169,000,000 won for the transfer value of the instant land, and the acquisition value of which is KRW 1,00,000,000 for the transfer income tax, and other necessary expenses, and submitted a sales contract (No. 169,000,000 for the transfer of the instant land to C around 2003) stating that “The Plaintiff shall transfer the instant land to C at KRW 1,169,00,000 for the transfer of the said land.”

E. However, on April 1, 2014, the Defendant: (a) deemed that the transfer value of the instant land was KRW 1,300,000,000 under the Act on the Establishment of a Fund, and other necessary expenses were not confirmed; and (b) applied 60/100, which is the tax rate of “unregistered transferred assets”; and (c) determined and notified the Plaintiff of the transfer income tax of KRW 387,828,00 (including additional tax) for the transfer income tax of 203.

F. On May 2, 2014, the Plaintiff appealed against the Defendant on May 2, 201, and the Defendant, on the 28th of the same month, filed an objection against the transfer value of the instant land in the contract form 1,169,000.