1. The Defendant’s transfer income tax amounting to KRW 69,479,640 (including additional tax) for the Plaintiff on November 5, 2013.

1. Details of the disposition;

A. On March 7, 2002, the Plaintiff acquired a field B 1,936 square meters, C 1,001 square meters, D 3,834 square meters, E 1,929 square meters (hereinafter “each of the instant farmland”), which is farmland in the Agricultural Promotion Area, and transferred it to the Korea Rural Community Corporation on December 14, 2012 (hereinafter “instant farmland”).

B. On December 26, 2012, the Plaintiff filed a tax base return on capital gains tax on the said transfer with the Defendant, and filed an application for reduction or exemption of capital gains tax on the premise that each of the instant farmland constitutes self-arable farmland (self-managed farmland in a period of three years or eight years or less).

C. From around 2009, the Defendant denied the Plaintiff’s satisfaction of the requirements for self-sufficiency for eight years while deeming that the Plaintiff did not own each of the instant farmland. Moreover, on the ground that each of the instant farmland does not constitute a recipient of management transfer subsidies, the Defendant denied the requirements for self-sufficiency for three years, thereby excluding capital gains tax reduction and exemption, and notified the Plaintiff of the correction of KRW 69,479,640 for the capital gains tax reverted to the year 2012 on November 5, 2013.

(hereinafter “instant disposition”) D.

The Plaintiff appealed and filed an appeal with the Tax Tribunal on May 22, 2014 on January 23, 2014, but was dismissed on November 20, 2014.

[Ground of recognition] Unsatisfy, Gap evidence 1, 13, 14, Eul evidence 1 (including each number; hereinafter the same shall apply), each statement, the whole purport of the pleading

2. Determination on the legitimacy of the disposition

A. The summary of the Plaintiff’s assertion is a farmer who did not engage in any other work except for a lifelong farmer, and the rice paddy field cultivated for 60 years was expropriated into a housing site district in 2001, and around that time, the Plaintiff has continuously engaged in agriculture by acquiring farmland equivalent to 19,403 square meters including each farmland of this case, including each farmland of this case and continuously engaging in agriculture.

However, while the health of the plaintiff's spouse is unsatisfy, it was cultivated by lending the labor force of G, a neighboring farmer in 2009 and around 2010.