1. Limit of KRW 28,346,902 to the sales contract concluded on February 13, 2014 with respect to real estate listed in the separate sheet by the Defendant and B.

1. Facts of recognition;

A. B, around November 2010, donated land D and 21 parcels of land (hereinafter “instant donated land”) from Gyeong-gun, Seongbuk-gun, Seongbuk-do (hereinafter “instant donated land”), and around September 2013, sold all of the instant donated land to a third party (hereinafter “sale of this case”).

B. On November 18, 2010, B submitted to the head of the competent tax office a report on the gift tax base and an invoice for payment of the gift tax on the instant donation on November 18, 2010, B entered the tax amount payable on the premise that the instant donation land constitutes farmland, etc. donated to a farming child by a self-employed farmer under the Restriction of Special Taxation Act, and the tax amount to be paid is KRW 0,000,000, under the condition that the tax amount would be reduced or exempted. On December 31, 2013, B submitted a report on the tax base of transfer income and a

However, B transferred farmland, etc. whose gift tax has been reduced or exempted within five years, thereby collecting the amount equivalent to the reduced or exempted tax amount, and C had the time of acquisition and necessary expenses calculated and imposed the transfer income tax by using the time of acquisition of the donated land.

On September 15, 2015, the head of the relevant tax office of Kimhae, who is the head of the competent tax office, determined the tax amount to be paid by B as KRW 142,146,242 in total (i.e., the amount to be collected at KRW 91,321,465, the amount to be collected at KRW 26,30,581, the amount to be paid at KRW 24,524,196, the amount to be paid by B for the sale of this case (i.e., the amount to be paid at KRW 82,496,456, the amount of capital gains tax to be paid at KRW 82,496,456, the amount to be paid at KRW 12,884,586, the amount to be paid at KRW 39,298,869, the amount to be paid at KRW 2969).

(hereinafter) The tax amount on the gift of this case determined and notified as above shall be referred to as “instant gift tax,” and the tax amount on the sale of this case shall be referred to as “the instant transfer income tax”).

On the other hand, "The real estate listed in the separate sheet owned by B is less than the real estate."