1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance, such as accepting the judgment of the court of first instance, is as stated in the reasoning of the judgment of the court of first instance, except to supplement or add the judgment as stated in the following (3). As such, it shall be cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. Following the five pages for the amendment, “The Income Tax Act amended (wholly amended on December 22, 1994)” in the following two categories: “The date of the last five separate acquisition” in addition to the “the date of the last five separate acquisition” [the assets (land or buildings) stipulated in subparagraph 1 of Article 94 and acquired on December 31, 1976 shall be deemed to have been acquired on January 1, 197].

3. Supplementary and additional Plaintiff asserts to the following purport:

Article 97 (1) 1 (b) of the Income Tax Act provides that where the acquisition value, which is one of the necessary expenses deductible from the transfer value in calculating gains on transfer, is to be “actual transaction value” and where it is impossible to confirm the actual transaction value at the time of acquisition, it shall be the transaction example value, appraised value or conversion value prescribed by Presidential Decree. Article 163 (12) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 24356, Feb. 15, 2013) provides that “The term “the transaction example value, appraised value or conversion value prescribed by Presidential Decree” in Article 97 (1) 1 (b) of the Act means the value under Article 176-2 (2) through (4)” and the main sentence of Article 176-2 (3) provides that “where the transfer value or acquisition value is determined or revised by estimation pursuant to Article 114 (7) of the Act, the method calculated by applying each of the following subparagraphs in sequence to the relevant appraisal corporation at least two months before or after the acquisition date” in subparagraph 2: