1. All of the plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

1. Details of the disposition;

A. The Plaintiffs were the owners of 1,540 square meters in the paddy-si, Kimhae-si (hereinafter “instant previous farmland”). As the said farmland was expropriated at the time of Kimhae-si on May 20, 201, the Plaintiffs acquired the land of 890 square meters in each of the shares of 1/2, respectively, on July 4, 2011.

B. The Plaintiffs filed an application for full reduction or exemption of KRW 10,809,945 in capital gains tax by applying the provision on reduction or exemption of capital gains tax under Article 70(1) of the former Restriction of Special Taxation Act (amended by Act No. 11133, Jan. 1, 2011; hereinafter the same) that prescribes reduction or exemption of capital gains tax when reporting the capital gains tax on the transfer of the previous farmland in 2011 following the transfer of the instant farmland,

C. In around 2015, the Defendant: (a) determined that the instant substitute farmland was used directly for self-defense; (b) determined that the Plaintiffs did not do so for more than three years; and (c) notified the Plaintiffs on December 18, 2015, that each transfer income tax of KRW 8,497,957, and KRW 12,674,217 should be imposed on each of the Plaintiffs on December 18, 2015 after denying the reduction or exemption of the previous substitute farmland and applying the reduction or exemption of the expropriation.

Accordingly, the plaintiffs filed an application for pre-assessment review but dismissed, and the defendant served a tax payment notice of KRW 12,672,217 on March 9, 2016 to each of the plaintiffs (hereinafter "each of the dispositions of this case"), and the plaintiffs appealed against it and filed an appeal with the Tax Tribunal on May 20, 2016, but was dismissed on August 31, 2016.

[Ground of recognition] The facts without dispute, Gap evidence 1 through 4, Eul evidence 1 to 3 (including each of the items with a lot number), the purport of the whole pleadings

2. The attachment to the relevant Acts and subordinate statutes shall be as follows;

3. Whether the instant disposition is lawful

A. The plaintiffs asserted that the substitute farmland of this case has been cultivated directly for not less than three years. Thus, income from the transfer of the previous farmland of this case is the transfer income tax due to substitute farmland of this case under Article 70 (1) of the former Restriction of Special Taxation Act.