1. The Defendant’s transfer income tax of KRW 67,246,90 (including additional tax) for the Plaintiff on November 2, 2015.

1. Details of the disposition;

A. The Plaintiff acquired a house and a house on August 26, 1980 in Jongno-gu Seoul Metropolitan Government B Dae-gu (hereinafter “instant land”) and a house on the ground, and transferred it to the Plaintiff at KRW 1950 million on May 18, 2015.

B. On July 4, 2015, the Plaintiff calculated the amount of transfer margin and special deduction for long-term holding pursuant to Article 95(2) and (3) of the former Income Tax Act (amended by Act No. 13426, Jul. 24, 2015; hereinafter the same shall apply) and Article 160(1) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 26302, Jun. 1, 2015; hereinafter the same shall apply). In particular, in calculating the amount of special deduction for long-term holding of the instant land, the Plaintiff reported and paid capital gains tax by applying the deduction rate of at least 10 years for the holding period of 10 years for one household prescribed in Article 95(2) Table 2 of the former Income Tax Act (hereinafter referred to as “mark 2”). Meanwhile, in calculating the amount of special deduction for long-term holding of the instant land, the Plaintiff reported and paid capital gains tax by applying the deduction rate of at least 80%.

C. However, on August 23, 2013, the Defendant: (a) deemed that the Plaintiff newly acquired a single-story house (64.86 square meters in a settlement area; hereinafter “second-story house”) in addition to the existing 2nd floor and the 1st basement house (hereinafter “the first house”) on the instant land; (b) in calculating the special long-term holding deduction amount for the instant land, the Defendant divided the instant land into the first house and the land annexed to the second house according to the ratio of the settled area for the first house and the second house; (c) in calculating the special long-term holding deduction amount for the instant land, the deduction rate of 80% for the first house holding period for the second house and the land annexed to the second house shall be applied; and (d) in applying the deduction rate of 30% for the second house holding period for the second house to the Plaintiff on November 2, 2015, the additional tax for the Plaintiff on November 2, 2015 (hereinafter “the additional tax”).