1. The plaintiff's claim is dismissed.

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

1. Basic facts

A. On June 29, 2004, the Plaintiff completed the registration of ownership transfer on the ground of sale on May 30, 2004, with respect to the total of 9,311 square meters of the land sites of Soju-gun-gun or E owned by the Plaintiff (hereinafter referred to as “instant land”) to 13 persons, including the Defendant (the name before the opening of the name: C) on May 30, 2004.

B. A two-time sales contract was formulated between the Plaintiff, the Defendant, etc. as follows.

1) On May 4, 2004, the buyer drafted a sales contract stating the purchase price of KRW 800 million (the contract amount of KRW 70 million on the date of the contract, the intermediate payment of KRW 250 million on the date of the contract, and the intermediate payment of KRW 480 million on June 4, 2004 until June 5, 2004, and each payment of KRW 480 million on July 5, 2004) (Evidence 4; hereinafter referred to as “first contract”).

(2) Between May 4, 2004 and June 4, 2004, the buyer prepared a sales contract by each site of KRW 550 million in total (from June 14, 2014 to June 21, 2004) on the grounds that the Defendant, etc. individually purchased each of the above sites, and the buyer prepared a sales contract by each site of KRW 50 million in total (from June 14, 2014 to June 21, 2004).

(A) Evidence Nos. 2-1 through 11, hereinafter referred to as the "second-party contract"). Each parcel shall be the buyer and the sales price as follows:

G, H, I, I 45 million won in the purchase price of each parcel of DF 96 million won, G, JJ L 〃 L 40 million won in KRW 440 million in KRW R S S 45 million in KRW 45 million in KRW e-Y, E Y, Z amounting to KRW 45 million in KRW WV, X 50 million in KRW 50 million in the purchase price of each parcel of land.

C. On September 12, 2014, the head of the Gyeonggi Mine District Tax Office reported and paid the transfer income tax with the transfer value of the instant land KRW 550 million to the Plaintiff, but as a result of the on-site investigation, imposed a disposition imposing the transfer income tax of KRW 263,133,70 (including additional tax) for the reason that the actual transfer value of the said land is KRW 800 million on the Plaintiff.

(hereinafter “instant disposition”). Accordingly, the Plaintiff filed a lawsuit seeking the revocation of disposition imposing capital gains tax under the Suwon District Court 2015Gudan1216 on the instant disposition, but the Plaintiff was ruled against the Plaintiff, and the Seoul High Court was dissatisfied therewith.