1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the court’s explanation concerning this case is as stated in the reasoning of the judgment of the first instance, except where the following parts are modified, thereby citing this in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

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C. Determination 1) According to Article 69(1) of the former Restriction of Special Taxation Act (amended by Act No. 13560, Dec. 15, 2015); Article 66(1), (11), and (13) of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 26070, Feb. 3, 2015), in order for a heir to obtain a reduction or exemption of capital gains tax on inherited farmland, it shall be determined as follows: (a) the heir has resided in a Si/Gun/Gu where the relevant farmland is located; (b) a Si/Gun/Gu where the relevant farmland is located; (c) an area within a Si/Gun/Gu where the relevant farmland is located; or within a 20km radius from the relevant farmland; and (d) a period of cultivation acquired by a decedent shall be at least eight years; and (c) the “direct cultivation” in this case means a person who is constantly engaged in cultivating crops or growing perennial plants on his/her own farmland; (d, 20131/201).

The land transferred as a building has been cultivated directly.