1. The Defendant’s imposition of capital gains tax of KRW 290,783,90 for the year 2005 against the Plaintiff on February 1, 2012, 188,369.

1. Details of the disposition;

A. The Defendant conducted an investigation with respect to the Plaintiff, and determined that “the Plaintiff reselled each real estate listed in the separate sheet from 2005 to 2007 (excluding the real estate Nos. 1, 2, and 8 among the above real estate) not yet registered” of the instant real estate. On February 1, 2012, the Defendant issued a revised notice of KRW 496,821,400, capital gains tax for the year 2005, capital gains tax for the Plaintiff 380,294,390, capital gains tax for the year 2006, and capital gains tax for the year 2007 415,472,020, respectively.

B. The Plaintiff appealed and filed an objection against the Defendant on April 27, 2012. On May 24, 2012, the Defendant rendered a decision to the effect that “the instant 1, 2, and 8 real estate is excluded from the object of transfer,” and that the amount of KRW 206,037,415 out of the transfer income tax reverted to the year 2005 and KRW 62,065,850 out of the transfer income tax reverted to the year 2006 was reduced, respectively.

C. On August 22, 2012, the Plaintiff appealed and filed a request for a trial with the Tax Tribunal. On December 20, 2012, the Tax Tribunal rendered a decision to the effect that “the transfer value of real estate 10,000 won is KRW 120,000, and the tax base and tax amount are corrected.” On January 2, 2013, the Defendant corrected the reduction of KRW 11,284,70 from the transfer income tax reverted to the year 2006.”

(hereinafter referred to as “instant disposition”), which was revised on February 1, 2012, is subject to the disposition of imposition of capital gains tax (hereinafter referred to as “instant disposition”). [Grounds for recognition] without dispute, entry into Gap’s 2 through 5 (including the number, hereinafter the same shall apply), Eul’s 1 through 4, and 14, and the purport of the entire pleadings.

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) The Plaintiff does not sell and sell each of the instant real estate, but arranged the sale and purchase of each of the instant real estate, and thus, the Plaintiff cannot impose capital gains tax on the Plaintiff. 2) The Defendant included the Plaintiff’s non-transferable real estate in the transfer subject matter, and calculated the acquisition value under-calculated or excessive transfer value of the real estate.