1. Revocation of a judgment of the first instance;

2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. On December 30, 199, the Plaintiff completed the registration of ownership transfer under the name of the Plaintiff with respect to B orchard B 13,486 square meters in Ansan-si.

Since June 30, 2011, the said land was divided into 6,874 square meters of B orchard and C orchard 6,612 square meters of the said land.

(hereinafter referred to as “instant land”) B.

On May 30, 201, the Plaintiff entered into a sales contract with D and E with respect to the instant land as KRW 500 million (Evidence 2-3), and completed the registration of ownership transfer (each share 1/2) in the name of D and E on July 6, 2011.

(hereinafter “transfer of this case”). (c) The transfer of this case

On September 30, 2011, the Plaintiff calculated the tax amount by applying Article 70 of the Restriction of Special Taxation Act and Article 67 of the Enforcement Decree of the same Act to the Defendant for the preliminary return and payment of capital gains tax on the transfer of this case.

(2) No. 2-D.

On November 28, 2011, the Plaintiff completed the registration of transfer of ownership in the name of the Plaintiff on the ground of sale on the 21st day of the same month with respect to FY 4,350 square meters in Gyeong-gun, Sung-gun, Chungcheongnam-gun, Gyeong-gun as the substitute farmland for the instant land.

E. On April 2013, the Defendant issued a prior notice of taxation that the Plaintiff did not directly cultivate the instant land at the time of the instant transfer, that the lessee G cultivated ma in the instant land, and denied the application of the farmland substitute land reduction and exemption provisions, and that on April 30, 2013, the Defendant imposed KRW 113,267,540 on the Plaintiff on April 30, 2013.

F. Accordingly, the Plaintiff filed a request for pre-assessment review on May 27, 2013, but the Defendant rendered a non-adopted decision on June 21, 2013, and issued a notice of correction and notification of capital gains tax amounting to 113,267,540 (including additional tax) for the Plaintiff on July 1, 2013 according to the pre-announcement of taxation.

(g) Evidence Nos. 2, 5, and 7 (hereinafter “instant disposition”). The Plaintiff appealed and filed an objection on July 23, 2013, but was dismissed on August 28, 2013.

The plaintiff re-motor vehicle.