1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On April 9, 1985, the Plaintiff acquired and owned B 20,321 square meters (hereinafter “instant farmland”) and transferred the instant farmland to public interest corporations, etc. on January 6, 201, and filed a preliminary return of transfer income tax on February 14, 2011, on the ground that the instant farmland constitutes self-farmland for eight years, on the ground that the said farmland constitutes self-farmland, and filed a return of transfer income tax of KRW 44,103,000,000, on the grounds that the said farmland constitutes self-farmland for eight years.

B. On June 10, 2013, after conducting a field investigation on the farmland of this case on the ground that the Plaintiff did not directly cultivate the farmland of this case for at least eight years, the Defendant denied the report of reduction and exemption of capital gains tax and special deduction for long-term holding, and issued the instant disposition to correct and notify the transfer income tax of KRW 90,591,440 (including additional tax) for the year 201.

C. On December 12, 2013, the Plaintiff filed an objection and filed an appeal with the Tax Tribunal. However, the Tax Tribunal dismissed the said appeal on May 13, 2014.

[Reasons for Recognition] Unsatisfy, Gap evidence 1-2, Eul evidence 5

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion 1) since acquiring the instant farmland on April 9, 1985, the Plaintiff actually resided in the location of the farmland and actually cultivated the instant farmland. Therefore, it constitutes reduction or exemption of capital gains tax on self-arable farmland pursuant to Article 69(1) of the Restriction of Special Taxation Act, and thus, does not constitute a non-business land, and thus, the special deduction for long-term holding should be applied. (2) The Plaintiff received a donation after receiving a registration of ownership transfer for the instant farmland from C, which was its father, for sale, and the said C acquired the instant land from the date of acquisition on April 1948, 200 to be self-employed for not less than eight years.

(b) as shown in the attached Form of the relevant statutes;

(c) the board 1.