1. The Defendant’s transfer income tax amounting to KRW 1,102,042,340 (including additional tax) for the Plaintiff on April 10, 2017.

1. Details of the disposition;

A. On December 18, 2015, the Plaintiff transferred the instant real estate to C 5 billion won, and completed the registration of transfer of ownership by receiving the sales price in full by February 3, 2016, the sales price was paid and completed by February 3, 2016.

(hereinafter “Transfer”). (Unit: 5,00,000 401,8723,688,430 2,950,7474 737,686 259,970

B. On the ground that the instant real estate owned for at least ten years constitutes one house for one household, the Plaintiff’s transfer margin equivalent to the ratio of KRW 900 million out of the transfer value is non-taxation gains, and the amount of special deduction for long-term holding is 80% of the transfer margin subject to taxation [the same shall apply to the instant real estate before it was amended by Act No. 14389, Dec. 20, 2016; hereinafter the same shall apply].

(2) Article 95(2) Table 2 of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 28293, Sep. 19, 2017; hereinafter the same shall apply)

) On April 30, 2016, the Defendant made a preliminary return of KRW 259,970,710 of capital gains tax as follows, and paid on May 2, 2016.

C. On April 10, 2017, the Defendant denied a non-taxation report on one house for one household on the ground that the instant building was a house on the public register and its actual use does not correspond to “house” as a neighborhood living facility, and applied 30% by applying the special deduction rate for long-term holding, the Defendant issued a notice to increase or correct the capital gains tax of 1,102,042,340 won (the total amount of KRW 916,154,581, and additional tax of 91,615,615,458, additional tax of 94,272,306) for the year 2016.

(hereinafter “instant disposition”) D.

On September 26, 2017, the plaintiff appealed to the Tax Tribunal, but was dismissed.

grounds for recognition.