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. The Plaintiff’s real estate transfer and taxation report 1) The Plaintiff, which was acquired around October 18, 1966, added up the said land to “the instant land” and owned by the Plaintiff 1,66 square meters prior to Gyeongbuk-gun, Chungcheongnam-gun, Chungcheongnam-do, Daejeon-gun, C, 2,095 square meters prior to C, and 859 square meters prior to D.

(2) On May 30, 2012, the Plaintiff: (a) sold Thai C&T Co., Ltd. and B&T on the same day; and (b) completed each registration of ownership transfer on the same day; (c) around July 31, 2012, the Plaintiff: (a) deducted KRW 74,366,228 from the special long-term holding deduction of KRW 74,36,227 from the transfer margin of the instant land; and (b) made a preliminary return of the tax base of capital gains by making the amount of KRW 45,832,420 as the capital gains tax base calculated by deducting the amount of KRW 74,36,228 from the special holding deduction

B. On November 1, 2012, the Defendant issued a correction notice of KRW 75,045,040 (including additional tax on negligent tax returns, KRW 2,078,944, KRW 1,980,498) for the year 2012, by excluding the application of special deduction for long-term possession and capital gains tax reduction and exemption on the ground that the Plaintiff did not meet the requirements for re-resident re-resident, etc. for at least eight years.

(hereinafter “instant disposition”). C.

On January 29, 2013, the Plaintiff asserted that the Plaintiff is subject to reduction or exemption of capital gains tax by requesting an adjudication to the Tax Tribunal, but was dismissed on August 14, 2013.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 2, 3, 28, 29, Eul evidence Nos. 1 and 2 (including various numbers), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion is: (a) around October 13, 1980, the Plaintiff cultivated bean in the instant land from around that time; (b) around February 26, 1984, the Plaintiff’s mother and her mother were living in other areas; and (c) around January 2001, the Plaintiff returned home and sold the instant land from around that time (e.g., May 30, 201), while residing in Gyeong-gun, Gyeongnam-gun, Gyeongnam-gun, in the instant land, and directly cultivated bean, spa, and ornamental trees, etc. from the instant land.