1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On October 10, 1984, the Plaintiff completed the registration of ownership transfer with respect to B 1,930 square meters (hereinafter “undivided land”).

B. Around December 2008, the land prior to subdivision was divided into 600 square meters in C warehouse site (hereinafter “instant land”) and 1,330 square meters in D.

On the other hand, on the ground of the instant land, there are 165.6 square meters of the sand position panel structure, sand position panel, and one-story agricultural products collection center of the first floor of the sand position panel roof, which was approved around January 4, 1996 (hereinafter "the instant building").

C. On February 11, 2009, the Plaintiff sold to Nonparty E the instant land and the instant building and the instant building on its ground, and D on February 20, 2009, and completed the registration of ownership transfer around February 20, 2009.

(Purchase price of the instant building under a sales contract: KRW 30,00,000, and KRW 40,400,000 for the purchase price of the instant land, and KRW 89,60,00 for D’s purchase price.

The Plaintiff did not report the transfer income tax on the instant land after such sale.

E. On May 8, 2012, the Defendant issued a notice of correction and notification of KRW 10,610,770 (including additional tax; hereinafter “instant disposition”) for capital gains tax belonging to 2009 by deeming that the instant land was not farmland at the time of transfer to be deemed not farmland and excluded capital gains tax reduction and exemption.

F. On November 25, 2013, the Plaintiff filed an appeal with the Tax Tribunal. The Tribunal rendered a decision that the Plaintiff’s appeal is dismissed on or around November 25, 2013, and the said decision was served on the Plaintiff on or around December 5, 2012.

[Ground of recognition] Unsatisfy, Gap evidence 1 through 7, 19, Eul evidence 1 and 2 (including each number), the whole purport of the pleading

2. Whether the disposition is lawful;

A. The gist of the Plaintiff’s assertion was that the Plaintiff cultivated vegetables or rice plants on its ground after acquiring the land before subdivision. On 195, the Plaintiff et al. became its members and thus, the Plaintiff et al. was able to borrow a loan under the name of the said partnership. The Plaintiff is the land before subdivision.