1. The instant lawsuit shall be dismissed.

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

1. Details of the disposition;

A. On October 17, 2006, the Plaintiff completed the registration of transfer of ownership in the Plaintiff’s name due to sale and purchase (hereinafter “instant land”) with respect to Hongcheon-gun, Hongcheon-gun, Hongcheon-gun, 2480 square meters of land (hereinafter “instant land”). On July 3, 2007, the Plaintiff completed the registration of transfer of ownership on the instant land due to sale and purchase (the transaction value of KRW 100,000,000 on the register).

(220,000,000 won on the register). The Plaintiff did not report the transfer income tax on the instant land to the tax authority.

B. On December 1, 2014, the Defendant decided to impose capital gains tax of KRW 107,892,149 (including additional taxes) on the instant land on the Plaintiff for the year 2007, and the service by public notice was effective on January 20, 2015 (hereinafter “instant disposition”), but the Plaintiff did not pay the same.

C. On July 15, 2019, the Plaintiff filed a request for a trial with the Tax Tribunal on the instant disposition, but the Tax Tribunal dismissed the Plaintiff’s request on the ground that the request for a trial was unlawful on October 21, 2019, because it was filed with the aim of the request period.

[Reasons for Recognition] A without dispute, Gap evidence Nos. 1 through 2 (including each number in case of additional number), Eul evidence Nos. 1 and 2, the purport of the whole pleadings

2. The Plaintiff asserted that Nonparty D lent the Plaintiff’s name to purchase and sell the instant land.

Since the Plaintiff is merely a title trustee of the instant land and did not belong to the Plaintiff, the instant disposition is unlawful under the principle of substantial taxation.

3. Determination on the defense prior to the merits

A. The defendant's assertion that the plaintiff filed a request with the Tax Tribunal for a trial with the lapse of the period of the request. Since the Tax Tribunal rendered a decision to dismiss the request, the lawsuit in this case is unlawful as it does not meet the requirements of the previous trial procedure

(b)in addition to the indication of the relevant provisions,

(c).