1. The Defendant’s KRW 30,040,217 as well as the Plaintiff’s annual rate from August 1, 2017 to November 1, 2018.

1. Basic facts

A. When the Plaintiff’s land and its ground, D land, E, F land, G land, H land, I land, J land, and K land were incorporated into a L Urban Development Project site, which is a public project, and was expropriated, the Plaintiff delegated the duty of reporting capital gains tax to the Defendant through the M Certified Tax Accountants affiliated with the Defendant on November 2015, and paid two million won to the Defendant based on remuneration.

B. On February 29, 2016, based on the result of consultation with the Plaintiff, the Ntax Accountants affiliated with the Defendant filed a preliminary return on the tax base of capital gains from the transfer of each real estate on behalf of the Plaintiff with the head of both tax office on behalf of the Plaintiff, and as to the above C-ground building (hereinafter “instant housing”), a non-taxation report on capital gains tax was filed to the effect that the said housing transfer is a transfer of one house per household.

C. However, the head of both tax office finds that the Plaintiff’s husband has a house in the place of another’s wife, and the Plaintiff is exempt from the transfer of one house by one household.

On July 1, 2017, the Plaintiff rendered a disposition to correct capital gains tax for the year 2015 to KRW 617,596,361, and impose penalty tax to KRW 54,618,578 (additional tax for the under-declaration of KRW 22,166,631, and penalty tax for the unfaithful payment of KRW 32,451,947). In addition, the local income tax was notified on the same day and the penalty tax was imposed to KRW 5,461,857 (additional tax for the under-declaration of KRW 2,216,662, penalty tax for the under-declaration of KRW 3,246,194).

The deadline for payment of capital gains tax and local income tax that has been subject to the above revised disposition is July 31, 2017, respectively.

[Reasons for Recognition] Facts without dispute, Gap evidence 1, 2, Eul evidence 1 to 4 (including each number), the purport of the whole pleadings

2. Determination

(a) A certified tax accountant who is delegated by a taxpayer with the vicarious bookkeeping for the return of taxes and by proxy for the return of taxes shall be bound by the care of a good manager depending on the principal place of delegation;