1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The Plaintiff purchased from B, C, and D the area of 793 square meters prior to the Gangseo-gu Busan Metropolitan City E (hereinafter “instant real estate”) and completed the registration of ownership transfer on October 14, 2004 with respect to the said real estate on October 12, 2004.

After that, the Plaintiff sold the instant real estate to F and completed the registration of transfer of ownership on January 5, 2012, which was caused by the sale on December 27, 2011, to F.

B. On April 2, 2012, the Plaintiff reported and paid capital gains tax of KRW 11,350,56,560,560 as the transfer value of the instant real estate, and acquisition value of KRW 456,456,00 (purchase value of KRW 456,00,000 and registration tax of KRW 456,00).

C. From April 27, 2017 to May 16, 2017, the Defendant conducted an on-site investigation of the Plaintiff’s capital gains tax, and determined that the actual transaction price at the time of acquiring the instant real estate was unclear on the grounds that there was no specific and objective evidence, such as financial materials proving that the acquisition price reported by the Plaintiff was higher than the neighboring land price and that the instant real estate was acquired as the acquisition price reported by the Plaintiff.

Accordingly, on July 3, 2017, the Defendant issued a correction and notification of KRW 142,214,860 (including additional tax) and local income tax 14,221,486 (hereinafter “instant disposition”) to the Plaintiff on the ground that the conversion price of the instant real estate was KRW 205,573,770 in accordance with Article 97(1)1 (b) of the former Income Tax Act.

The Plaintiff dissatisfied with the instant disposition and filed an administrative appeal on September 13, 2017, but was dismissed on November 30, 2017.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 3, 9, 10, 11, Eul evidence Nos. 20, 22, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s instant disposition is unlawful for the following reasons.

1. The Plaintiff actually paid 456,000,000 won to the transferor.