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 grounds for admitting and amending the judgment of the court of first instance are as stated in the reasoning of the judgment of the court of first instance, except where the court of first instance used two to six to ten from the 5th 18th am of the judgment of the court of first instance as follows. Thus, they are cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

[Supplementary Provisions] The phrase “non-declaration of tax without filing by an improper means” under Article 47-2(2)1 of the former Framework Act on National Taxes (amended by Act No. 11124, Dec. 31, 201) is a requirement for imposing an unfair additional tax on non-declaration of tax

In a case where a return of tax base is not filed by an active act such as making it difficult to discover a false fact or forging false facts, it shall be deemed that such a return results from the purpose of tax evasion, such as the avoidance of progressive tax rates and the application of the provisions on loss brought forward.

(See Supreme Court Decision 2013Du12362 Decided November 28, 2013). In light of the following circumstances, the Plaintiff’s non-declaration of capital gains tax is deemed to have added the overall purport of the pleadings to the respective descriptions of evidence Nos. 1, 3, 4, and 6, the Plaintiff’s non-declaration of capital gains tax should be taxed.

It is judged that the purpose of tax evasion is attributable to the active act such as making it difficult to discover the facts or forging false facts, which is caused by the purpose of tax evasion.

Therefore, it cannot be deemed that there is any error in the imposition of unfair non-declaration penalty tax among the dispositions in this case.

The plaintiff's assertion on this part is without merit.

The Plaintiff purchased the instant real estate from the clan, and then made a sales contract to be prepared as if the Plaintiff entered into a direct sales contract between the instant clan and D and F, the final buyer.

Furthermore, the registration of ownership transfer of the real estate of this case is directly made to D and F as the final buyer from the clan of this case, the seller.