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.

1. Details of the disposition;

A. On June 30, 2003, the Plaintiff completed the registration of ownership transfer for the instant land on January 15, 2004, with respect to the 533/98 shares out of the Seo-gu Daejeon District Court Decision 307.1 square meters (hereinafter “instant land”). On April 14, 2004, the Plaintiff completed the registration of ownership transfer for the instant land on April 14, 2004, with respect to the 455/98 shares among the instant land.

B. On the instant land, the Plaintiff newly constructed a multi-family house with the 4th floor of steel reinforced concrete (refluor), a multi-family house with the 151.92m2, a multi-family house with the 2nd class neighborhood living facilities with the 2nd class neighborhood living facilities with the 151.8m2m2, a multi-family house with the 3rd floor (one household) and 128.82m2, a multi-family house with the 4th floor (one household), and a multi-family house with the 81.07m2m2 (hereinafter “instant building”) on December 20, 2003, and completed a registration of ownership preservation on April 14, 2004.

C. On June 24, 2004, the Plaintiff filed a preliminary return on capital gains tax with the Defendant, “The acquisition value of the instant land is KRW 226,213,750, the acquisition value of the instant building is KRW 156,76,712, and the transfer value of the instant real estate is KRW 400,000,000, the calculated tax amount is KRW 1,275,131, and the amount of tax to be paid voluntarily, KRW 1,147,618.”

As a result of the tax investigation with respect to the Plaintiff, the Defendant determined that the Plaintiff underreported the actual transfer value of the instant real estate. The Defendant imposed the instant disposition imposing KRW 179,960,242 upon the Plaintiff on September 7, 2012, adding the total of KRW 96,378,236 and KRW 75,582,006 for additional tax on negligent tax returns to KRW 181,147,618, which are calculated based on the actual transfer value of the instant real estate 590,00,000,000 for additional tax on negligent tax returns to KRW 181,147,618.

E. The Plaintiff’s instant disposition on September 20, 2012.