1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. Details of the disposition;

A. On August 196, the Plaintiff: (a) around August 1996, the Plaintiff acquired and transferred the instant land; (b) around 1996, the Plaintiff was a total of 6,803 square meters of the area of 922 square meters, D previous 2,653 square meters, E previous 1,542 square meters, and a total of 1,686 square meters of the F. (hereinafter “instant land”).

) The sales contract was concluded to purchase (hereinafter “instant sales contract”).

(2) The Plaintiff entered into a title trust agreement with G, H, and I on August 2, 1996, and completed the registration of ownership transfer with respect to the instant land as co-ownership by G, H, and I on the grounds of the sales contract executed on August 21, 1996.

3) The Plaintiff divided the instant land into ten parcels on March 16, 2012, and sold 6,607 square meters among the instant land to the buyers from April 2012 to June 2012 (hereinafter “instant transfer”). From April 2012 to June 2012, the Plaintiff sold 1,54,294,80 square meters among the instant land (hereinafter “instant transfer”).

2) On June 23, 2012, the Plaintiff filed a return on the tax base of capital gains tax for the transfer of this case with the Defendant on June 23, 2012, the Plaintiff: (a) acquired KRW 6,607 square meters from the instant land in KRW 1,364,583,360; and (b) reported and paid the capital gains tax calculated accordingly; (c) the Seoul Seodaemun Tax Office (hereinafter “Investigation Office”) issued a tax investigation on the Plaintiff around May 2017, confirmed the fact that the acquisition value of the instant land reported by the Plaintiff was unclear; and (b) the investigating office notified the Defendant of the determination that the acquisition value of the instant land was KRW 409,464,270, the converted value of the instant land.

2) Accordingly, on August 10, 2017, the Defendant calculated gains from transfer on the ground of calculating the following tax amount, and notified the Plaintiff of KRW 727,373,160 of the transfer income tax for the year 2012 (hereinafter “instant disposition”).

A. The transfer date’s transfer date’s acquisition value shall be the sum of the tax base notified tax amount by aggregating the transfer date’s acquisition value and transfer margin, and 1,544,29,469.