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 December 31, 201, the Plaintiff purchased and owned B B large 242.3 square meters and its underground floors, and the 5th floor above ground (hereinafter collectively referred to as “instant real estate”) from the Government-si from E, F, and G on December 31, 201, and transferred the pertinent real estate to C and D on November 22, 2002.

B. On January 30, 2003, the Plaintiff reported and paid KRW 757,156 of the capital gains tax calculated by applying the transfer value to KRW 737,00,000, acquisition value as well as KRW 710,000,00, while filing a preliminary return on the tax base of capital gains tax on the instant real estate.

C. On June 8, 2012, on the ground that the actual transfer value of the instant real estate was confirmed to be KRW 850,00,000, the Defendant notified the Plaintiff of the imposition of capital gains tax of KRW 116,212,220 [the calculated tax amount = KRW 43,262,568 additional tax of KRW 73,790,939 (additional tax of KRW 4,071,549 for additional tax of KRW 69,719,220 for additional tax of KRW 4,00), various deductible tax amounts (legal deductions), KRW 841,284, and KRW 10 for additional tax of KRW 841,284, and KRW 10 for additional tax of KRW 2,546,370 for correction on September 17, 2012, the details related to the disposition were corrected and corrected (hereinafter “instant disposition”).

Meanwhile, the Plaintiff filed an appeal with the Tax Tribunal on August 31, 2012, but the Tax Tribunal dismissed the Plaintiff’s appeal on November 13, 2012.

【Fact-finding without a dispute over the basis of recognition, Gap evidence 1 through 7, Eul evidence 1, 2, 5-4 through 7, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. In the event that the principal tax and the additional tax are imposed along with the summary of the Plaintiff’s assertion, the Plaintiff, who is a taxpayer, should be informed of the details of each taxation, by classifying the relevant tax amount and the grounds for calculation. The Defendant’s instant disposition was conducted upon the single tax payment notice.