1. Revocation of a judgment of the first instance;

2. The Defendant’s transfer income tax attributed to the Plaintiff on May 20, 2013 286,779.

1. Details of the disposition;

A. On February 3, 1989, the Plaintiff acquired and owned 1,652.5/124,595/124,00 of co-owners’ share in B forest land (hereinafter “instant land share”) and owned 1,652.5/124,595/124,00 of the co-owner’s share in 124,595/30,000 (hereinafter “instant land share”) on September 28, 2007 and November 14, 2007, the Plaintiff transferred the instant share in the instant land to Seori-ro Lael and E Co., Ltd. in total to KRW 300,00,000 of the transfer value (267,000,0000,000 of share in C, and KRW 33,300,000 of share in D).

(hereinafter referred to as “transfer of this case”). (b)

When the Plaintiff reported the transfer income tax on the transfer of this case, the transfer value shall be KRW 300,000,000, which is the actual transaction value, and the acquisition value shall be KRW 297,50,000,000, which is the conversion value.

C. The Commissioner of the National Tax Service confirmed the purchase price of G and H from February 1, 1989 to March 1, 1989 and notified the Defendant that the acquisition price should be calculated and taxed as a transaction example.

Accordingly, on May 20, 2013, the Defendant revised and imposed the Plaintiff KRW 286,779,520 (including penalty tax of KRW 17,445,071 and penalty tax of KRW 94,883,743 for failure to report) of the transfer income tax for the year 2007 (hereinafter “instant disposition”).

On December 4, 2013, the plaintiff appealed to the Tax Tribunal, but was dismissed on the other hand.

[Ground of recognition] Facts without dispute, Gap evidence 2 and 7, Gap evidence 11-1, 2, Eul evidence 1 and 2

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion (1) Each sales contract in the name of G and H, which is the basis of transaction example transactional transactions, is merely a so-called approval seal contract prepared for the convenience of taxation.

The purchase price stated in each of the above sales contracts is less than 1/10 of the officially assessed individual land price as of January 1, 1990, and the land price of this case is less than the Plaintiff’s share in the land of this case.