1. All of the plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

1. Details of disposition;

A. On December 31, 2002, the Plaintiffs transferred the right to sell the instant apartment to E and F (hereinafter “E”) under the condition of unpaid KRW 14,950,068 out of the sale price on December 27, 2006, under the status of unpaid KRW 14,950,068 out of the sale price, after acquiring from D the right to sell the instant apartment from Songpa-gu Seoul Metropolitan Government 101,208 (hereinafter “instant apartment”).

B. On February 28, 2007, the plaintiffs applied the transfer income tax rate on the transfer of the right to purchase the apartment of this case by deeming the transfer of the right to purchase the apartment of this case as a transfer of the right to purchase the apartment of this case and paid the tax amount after filing a final

C. On October 1, 201, the Defendant: (a) deemed the transfer of the instant sales right as an unregistered transfer asset; and (b) applied the tax rate for unregistered transfer assets on October 1, 201, imposed KRW 201,50,890 of the transfer income tax for the year 2006 on Plaintiff A; and (c) imposed KRW 200,068,610 of the transfer income tax for the year 2006 on Plaintiff B (hereinafter “each of the instant dispositions”).

The Plaintiffs had completed the procedure of the pre-trial trial.

[Reasons for Recognition] Unsatisfy, Gap evidence 7, 8, Eul 1, 2 (including each number), the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The gist of the plaintiffs' assertion is that the Enforcement Decree of the Income Tax Act, in principle, stipulates the time of the transfer or acquisition of assets. The plaintiffs' right to acquire real estate is not yet paid in full at the time of the transfer of the sales right of this case, and since the plaintiffs' right to purchase the apartment of this case was not acquired, the transfer of the sales right of this case is unlawful as it violates the principle of no taxation without law and strict interpretation.

B. The plaintiffs entered into a sales contract with D to purchase 123,754,500 won (63,754,500 won for the sales contract, 60,000 won for the sales contract, 60,000 won for the sales contract) on December 13, 2002, and then paid the full amount of the price on December 31, 2002.