1. The plaintiff's claim is dismissed.

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

1. Details of disposition;

A. On February 3, 1989, the Plaintiff acquired 3,305.4 square meters of forest B 124,595 square meters (hereinafter “instant land”) in Sungnam-si, Sungnam-si, and transferred the same to C Co., Ltd. on September 28, 2007.

B. On November 30, 2007, the Plaintiff reported and paid the transfer income tax on the instant land. The transfer value is KRW 600,000,000, which is the actual transaction value, and the acquisition value was KRW 597,000,000, which is the conversion value on the ground that the evidential documents were destroyed by fire. The Defendant calculated the acquisition value of the instant land by the transaction example amounting to KRW 13,49,254, which is calculated as the amount equivalent to KRW 4,083.7,00,000, based on the transaction example, the Defendant issued a disposition to correct and notify the transfer income tax for the year 2007, including the additional tax for the transfer income tax for the year 2007 (hereinafter “instant disposition”).

C. On August 14, 2013, the Plaintiff filed an appeal for adjudication against it, but received a decision of dismissal from the Tax Tribunal on December 4, 2013.

[Ground of recognition] without any dispute, Gap evidence 1 through 4, Gap evidence 12-1, 2, Eul evidence 1, and the purport of whole pleadings

2. Whether the disposition is lawful;

A. (1) The Plaintiff’s assertion (1) The acquisition value for calculating gains on transfer under the income tax-related Acts and subordinate statutes is based on the actual transaction example, appraisal value, and conversion value in a case where it is impossible to confirm the actual transaction value at the time of acquisition.

Each of the above methods is stipulated on an equal and parallel basis, and there is no provision to view that the above method is applied in sequential order, and thus, it is reasonable for the Plaintiff to calculate the acquisition value of the land of this case by the conversion value among them. The Defendant’s calculation of acquisition value by transaction example without any legal basis and calculation of the acquisition value by transaction example

(2) Each sales contract in the name of D and E, which is based on the example of business example, is merely a so-called "written approval" contract made in a lump sum for tax convenience.