1. The Defendant’s transfer income tax of KRW 118,069,441 (including additional tax) for the Plaintiff on October 1, 2013.

1. Details of the disposition;

A. On June 29, 2005, the Plaintiff and Nonparty B completed the registration of ownership transfer made on May 16, 2005 with respect to 1/2 shares of co-ownership among the 19,835 square meters of Chungcheongnambuk-do D Forest (hereinafter “instant forest”).

(B) Of the forest land of this case, the Plaintiff’s 1/2 shares (hereinafter “instant real estate”).

On November 19, 2007, E-L (hereinafter referred to as “E-L”) completed the registration of ownership transfer for the entire forest land of this case from the Plaintiff and Nonparty B on October 15, 2007.

C. The plaintiff B.

After the transfer, the Defendant reported and paid KRW 7,155,000 as capital gains tax calculated by applying the transfer value to KRW 150,000,000, and the acquisition value to KRW 135,00,00, when filing a preliminary return on the tax base of capital gains tax on the instant real estate after the transfer as stated in the same paragraph.

On October 1, 2013, the Defendant issued a revised notice of the increase in KRW 118,069,441 (i.e., KRW 125,224,441 (= KRW 125,224,441 - 7,155,000) of the capital gains tax that was already reported and paid by the Plaintiff on the ground that the actual transfer value of the instant real estate was 265,00,000).

(hereinafter “instant disposition”) e.

On December 27, 2013, the Plaintiff, who was dissatisfied with the instant disposition, requested a trial to the Tax Tribunal, but was dismissed on April 8, 2014.

[Ground of recognition] Unsatisfy, Gap evidence 1, 2, 7, Eul evidence 1 and 2 (including each number), the whole purport of oral argument

2. Whether the disposition is lawful;

A. The Plaintiff asserted that the Plaintiff acquired the instant real estate in the name of the Plaintiff in the position of the title trustee, but since the economic benefits from the acquisition of real estate belongs to Nonparty F Co., Ltd. (the Nonparty G, the husband of the Plaintiff, was actually operated by Nonparty G, and hereinafter “Nonindicted Co., Ltd.”), all of which are the title truster, the Plaintiff is the actual transferor of the instant real estate.