1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

The court's explanation of this case is consistent with the reasoning of the judgment of the court of first instance except for additional determination as follows. Thus, this Court shall accept this case in accordance with Article 8 (2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

Up to 13 degrees 13 to 16 lines shall be modified as follows:

① Certified Tax Accountants J, acting on behalf of the Plaintiff, confirmed a copy of the register of the real estate acquired in this case’s transfer land, provided that the Plaintiff should report the acquisition of the land in this case to the Plaintiff at a successful bid price with the knowledge of the fact that the Plaintiff acquired it by auction, and provided documents verifying the successful bid price in the court and viewing. The following is added to two pages of the 8th page

The plaintiff asserts to the effect that there are justifiable grounds, as the first and second instances of the same land ( July 8, 2014) and the second instances ( November 24, 2014) have paid taxes at the conversion price even at the time of transfer by consultation acquisition.

According to the aforementioned evidence, the Plaintiff transferred 1,117/10 of the acquired land of this case at the time of the Government of Jung-gu on July 8, 2014 on the grounds of consultation, and transferred 106,974/10 of the acquired land of this case to the Government of Jung-gu on November 24, 2014 for the same reason, and then returned and paid the transfer income tax on the converted value rather than the successful bid price.

However, the instant disposition was issued by the Seoul Regional Tax Office as a result of comprehensive audit of the transfer income tax belonging to year 2015 by the Seoul Regional Tax Office, not an individual consolidated investigation against the Plaintiff, and the grounds for rectification were clearly stated. Since the tax authorities could rectify the tax base and tax amount at any time within the exclusion period for national tax imposition, there was no corrective disposition on each transfer income tax belonging to the year 2014, and the acquisition value at the time of reporting the transfer income tax belonging to the land of this case for which the acquisition was reported for 201