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 January 11, 1983, the Plaintiff acquired B forest land B 8,628 square meters (hereinafter “instant land”). On July 6, 2005, the Plaintiff completed the registration of ownership transfer on the instant land on the ground of sale and purchase on April 28, 2005, and on July 26, 2005, reported and paid the transfer income tax to the Defendant with the transfer value of KRW 250,000,000,000.

B. On June 21, 2013, the instant land was subdivided into KRW 5,274 square meters of forest land and KRW 3,354 square meters of D forest land. On April 1, 2015, C completed the registration of transfer of ownership on the ground of sale and purchase on the ground of E and F on February 11, 2015, and on June 30, 2015, C scheduled transfer income tax on the transfer price of the instant land to KRW 250,000,000, accompanied by a sales contract (certificate No. 2; hereinafter “instant sales contract”).

C. Accordingly, the Defendant calculated gains on transfer of the instant land by taking the transfer price of KRW 650,00,00 as the actual transaction price at the time of the transfer of the instant land as the actual transaction price, and calculated gains on transfer of the instant land by taking the tax base of April 18, 2016 as KRW 349,818,637, and revised the total determined tax amount as KRW 193,670,673 (including additional tax of KRW 83,72,377) from the above tax amount to KRW 15,092,950, which remains after deducting the already paid tax amount of KRW 4,286,413 from the above tax amount as the actual transaction price at the time of the transfer of the instant land.

(hereinafter “instant disposition”) D.

On July 13, 2016, the Plaintiff filed an objection on July 13, 2016, and the application was dismissed on August 17, 2016, the Plaintiff again filed an appeal with the Tax Tribunal on October 4, 2016, but the Tax Tribunal rendered a decision to dismiss the Plaintiff’s claim on December 5, 2016.

【Ground of recognition” without any dispute, Gap's evidence 1, 3, 4, 5, Eul's evidence 1, 2, 3, and 7 shall include the number; hereinafter the same shall apply.

The authenticity of the evidence 1, 2, and 3 of this title shall be made by the witness C.