1. All of the plaintiff's claims are dismissed.

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

1. Details of the disposition;

A. On January 30, 2001, the Plaintiff acquired the farmland of this case as a voluntary auction, and completed the registration of ownership transfer for 1/3 of the shares of each of the farmland of this case to C and D on February 4, 2015, respectively, on December 4, 2014.

B. On February 6, 2015, the Plaintiff filed an application for reduction or exemption of capital gains tax under Article 69 of the former Restriction of Special Taxation Act (amended by Act No. 13560, Dec. 15, 2015; hereinafter “former Restriction of Special Taxation Act”) on the ground that “the Plaintiff is a self-employed farmland for at least eight years,” and filed a return on the tax amount to be voluntarily paid at zero won.

C. After conducting on-site verification and on-site investigation, the head of Jungsan District Tax Office denied the tax amount reduced or exempted by deeming that the Plaintiff did not directly cultivate the instant farmland, and on November 12, 2015, the Plaintiff issued a notice of correction and notification of KRW 286,420,510 (i.e., capital gains tax amounting to KRW 265,265,54, additional tax amounting to KRW 21,154,958), and local income tax amounting to KRW 28,642,050 (hereinafter “instant disposition”).

On February 11, 2016, the Plaintiff appealed to the Tax Tribunal, but the Tax Tribunal dismissed the Plaintiff’s claim on May 16, 2016.

[Ground of recognition] Facts without dispute, Gap evidence 1 through 10, Eul evidence 1 to 3, Eul evidence 1 and 2 (including each number; hereinafter the same shall apply), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff's assertion that the farmland of this case was directly cultivated for not less than eight years, and the disposition of this case is unlawful.

(b) Entry in the attached Form of relevant statutes;

C. Article 69(1) of the former Restriction of Special Taxation Act provides that “The transfer of land prescribed by Presidential Decree, among land cultivated directly by a resident prescribed by Presidential Decree who resides in the seat of farmland for at least eight years.”