1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

The first instance court.

Details of the disposition

① The Plaintiff’s father’s husband’s loss owned the instant land, but the Plaintiff completed the registration of ownership transfer on May 27, 1997 as to the instant land on April 30, 2003, on the ground of an inherited property agreement division as of April 30, 2003, and on November 21, 2008, on November 21, 2008, the registration of ownership transfer was completed on April 30, 2003, on the instant land as of November 21, 2008, on the ground of a trade division as of November 8, 2008.

② The Plaintiff did not report the capital gains tax base following the transfer of the instant land.

On January 2, 2012, the Defendant deemed the time of acquisition of the Plaintiff’s land of this case as of April 30, 2003, which was the date of division of inherited property, and calculated gains on transfer by calculating acquisition value of 210,241,800 according to the standard market price at that time, and notified the Plaintiff of the calculated amount of capital gains tax for fiscal year 2008, applying 60% of the heavy tax rate of 41,761,148 and additional tax of 212,01,01,174 in total, 653,762,322 won in calculation (i.e., principal tax of 441,761,148 + additional tax of 212,01,174) or below, and notified the amount of capital gains tax of 653,762,320 won in total,00 won in calculation.

(A) No. 1, No. 1, and 2 were determined and notified.

③ On January 27, 2012, the Plaintiff filed a request for review with the Board of Audit and Inspection on January 27, 2012, but the said request was dismissed on July 3, 2012.

④ On October 15, 2013, the Defendant revoked ex officio the portion of the disposition imposing capital gains tax, which was originally issued on January 2, 2012, and notified 212,01,174 won (=additional tax amounting to KRW 88,352,229, KRW 123,648,945), or KRW 212,01,174,00, based on calculation, by specifying the type of and basis for calculation of such additional tax (=additional additional tax amounting to KRW 88,352,229, KRW 129,645), or KRW 212,01,174

(3,4) Nos. 4-3, 5 (4), 50

As of January 2, 2012, the imposition of principal income tax as of January 2, 2012 and the imposition of penalty tax as of October 15, 2013 are added to the Plaintiff.