The judgment of the first instance shall be revoked.

2. Article 1(1) of the Seoul Regional Tax Office’s Act (attached Form 1) against the Plaintiff on March 1, 2017.

1. The facts below the disposition of this case do not conflict between the parties, or are recognized by comprehensively taking account of the overall purport of the arguments in Gap evidence Nos. 1 through 16, 19, and Eul evidence Nos. 1, 2, 3, and 5 (including the serial numbers).

[1] On February 10, 2004, D completed the registration of ownership transfer with respect to the 191m2 and 657.9m2 (hereinafter referred to as the “instant land”) of Gangseo-gu Seoul Metropolitan Government Ega 1911m2 and 657m2 (hereinafter referred to as the “instant land”).

D owned the 4th floor building of amusement facilities, neighborhood living facilities, offices, etc. (hereinafter “instant building”) constructed on the instant land, and partially leased the building to J, I, B, and C.

B and C are children of D.

D) Of the instant building, part 132.23 square meters in part of the first floor is leased to J a deposit of KRW 5 million and KRW 5 million in monthly rent of KRW 898.96 square meters in part to I, a deposit of KRW 30 million in monthly rent of KRW 20 million, KRW 50 million in part of the first floor and KRW 526 square meters in monthly rent to B and C, and KRW 7 million in monthly rent of KRW 528.30 and KRW 587.80 in four stories in three floors and KRW 587.80,000 in monthly rent of KRW 20 million in deposit to B.

[2] On April 21, 201, G Co., Ltd. (hereinafter “G”) entered into a contract with D to purchase the instant land and buildings with the price of KRW 24 billion (Evidence A 2).

Article 5 of the contract prepared at the time of the conclusion of the contract at the time of the above contract stipulates that D shall be resolved when there are grounds to restrict the exercise of owners such as mortgages, superficies, leases, etc. established on the land and buildings of this case, or when there is any unpaid amount

On the other hand, the terms of the above contract stipulated as follows:

1. The terms and conditions of the special agreement shall take precedence over all the terms and conditions of the contract, and shall be in breach of the contract unless otherwise agreed.

2. A contract for the purchase and sale of facilities according to the name map of the building in this case shall be entered into by the Fund for the Settlement of Disputes and the Fund for the Settlement of Disputes shall directly pay the name map to the lessee.

3. The sale and purchase of facilities and equipment with G and lessee; and