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1. The plaintiff's appeal and the defendant's appeal are all dismissed.
2. The costs of appeal shall be borne by each party.
purport, purport, and.
Reasons
1. Details of the disposition;
A. On September 24, 1972, the Plaintiff was appointed as a local public official for Kimhae-si, and retired from office in B/Myeon office, etc. from January 5, 1973 to June 22, 1995, and thereafter retired from office on July 30, 2007, and thereafter retired from office in 2009.
B. On October 13, 1978, the Plaintiff is the Plaintiff’s forest 27,570 square meters [the E forest 8,668 square meters and F forest 557 square meters (hereinafter “each of the instant forest”) via multiple subdivisions.
A) The ownership of the instant tree was acquired by dividing it into others, etc., and the trees (hereinafter “instant trees”) were planted in each forest of this case from that time.
C. On June 8, 2012, the Plaintiff sold each of the instant forest land to G Co., Ltd. (hereinafter “G”) and received full payment from G by September 13, 2012.
On November 30, 2012, the Plaintiff calculated the transfer value of each forest of this case as KRW 3,606,689,500, the transfer income amount as KRW 2,500,182,651, and the calculated tax amount as KRW 925,219,407, the Plaintiff reported and paid KRW 725,219,40,000, by applying the reduced or exempted tax amount for farmland for at least eight years under Article 69 of the Restriction of Special Taxation Act and Article 66 of the Enforcement Decree of the Restriction of Special Taxation Act.
E. However, on June 1, 2013, the Defendant issued a correction and notification of KRW 210,980,000 (including additional tax) for the transfer income tax corresponding to the year 2012, on the ground that “the Plaintiff was confirmed to have cultivated the instant pine trees by using his family and human father, and the Plaintiff does not directly seem to have existed for at least eight years in each forest of this case” to the Plaintiff.
(hereinafter “instant Disposition 1”). In addition, on September 1, 2013, the Defendant rendered the Plaintiff a total of KRW 3,906,689,500 on the transaction value on the real estate registration of each of the instant forests and fields, and the Plaintiff transferred each of the instant forests and fields collectively, while transferring each of the instant forests and trees, KRW 300 million in value of the instant trees.