1. The Defendant’s transfer income tax amounting to KRW 52,179,800 (including additional tax) for the Plaintiff on January 6, 2014.

1. Details of the disposition;

A. On February 8, 2007, the Plaintiff: (a) acquired and owned the instant building on the grounds of inheritance, including the instant land and the instant building, from his husband’s husband B, for the purpose of inheritance, KRW 619 million (hereinafter “instant real estate”); and (b) transferred the instant real estate to D on December 13, 201, in total, KRW 619 million.

B. Since January 31, 2012, the Plaintiff filed a report on the transfer of the instant real estate on January 31, 2012, included part of the non-taxable housing (building 67.9 square meters and land 25.875 square meters) in the case of the instant real estate, which is a limited real market price, in which the transfer value of the instant real estate is exempted. In calculating the transfer value, the Plaintiff derived the amount in proportion to the transfer value of the instant real estate according to the ratio of the standard market price of the said non-taxable housing as at the time of transfer and the standard market price of the portion excluding

The acquisition value of the instant real estate shall be 339,210,562 won, which is the amount calculated by deducting the market price of non-taxable housing (67.9 square meters of a building and land equivalent to 25.875 square meters of a building) from the average value of the appraised value of the value of the real estate assessed by two appraisal institutions (the temporary appraisal corporations of the company, the Japanese Appraisal Corporation) with respect to the instant real estate, and KRW 30,726,01 of capital gains tax calculated thereby was voluntarily paid to the Defendant.

C. Accordingly, on January 29, 2014, the Defendant applied KRW 253,731,00, which is the standard market price at the time of inheritance, to the Plaintiff on the ground that “The acquisition value of the instant real estate on which the Plaintiff reported the tax base of capital gains tax is based on the retroactive appraisal amount, and cannot be recognized as acquisition value.”