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 June 16, 2005, the Plaintiff entered into a sale contract with B Co., Ltd. (hereinafter “B”) on a total of 28 lots of land, including Osan-si Forest and Forest, located within the land transaction permission zone (hereinafter “instant land”) with the purchase price of 58.5 billion won in neighboring four lots of land (hereinafter “the instant primary contract”). Around December 2006, the Plaintiff entered into a sale contract with the purchase price of 44.5 billion won (hereinafter “the instant secondary contract”).

B. On May 31, 2007, the Plaintiff paid the forest income tax of KRW 12 billion to the Defendant on May 31, 2007 under the instant secondary contract. When the instant land was cancelled in the land transaction permission zone, the Plaintiff reported the transfer income tax to the Defendant on July 27, 201 with the transfer value of the instant land as KRW 32.5 billion.

C. Upon investigating the tax offense against the Plaintiff, the director of the Seoul Regional Tax Office confirmed the actual transfer value of the instant land as KRW 58.5 billion, and deemed that the Plaintiff prepared a false double contract, thereby filing a complaint with the Seoul Central District Public Prosecutor’s Office on September 4, 2013, against the Plaintiff as a suspicion of tax evasion, and notified the Defendant of the taxation data.

Accordingly, on February 5, 2014, the Defendant notified the Plaintiff of KRW 8,255,447,903 of the transfer income tax attributed to the year 2006.

(hereinafter “Initial Disposition”). On April 23, 2014, the Plaintiff appealed to the said taxation disposition and filed an objection on April 23, 2014, but was dismissed, and filed an appeal with the Tax Tribunal on September 11, 2014.

The Tax Tribunal shall:

In the first instance court of the criminal case (hereinafter referred to as "related criminal case"), the revised indictment is changed to the effect that "the actual transfer value of the land of this case is 4.5 billion won, but the false forest trees expenses are 12 billion won as forest income and the transfer income tax was evaded."