1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

1...

1. The reasoning of the court’s explanation concerning this case is as stated in the reasoning of the judgment of the court of first instance, except for the addition or dismissal of the judgment of the court of first instance as follows. Thus, this is accepted in accordance with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

The fifth of the judgment of the first instance court stated that the tax authority imposed corporate tax on the non-party company that is a purchaser, and recognized the purchase price of the pertinent land and building as the market price of KRW 1,316,910,000 (including deposit money for lease on a deposit basis), not the market price of KRW 1,316,910,000 (in imposing corporate tax on the non-party company that is a purchaser). However, the judgment of the court of first instance did not deny the effects of the agreed juristic act between the parties or modify or alter the existing juristic act, and the taxation on the opposite party who received profits equivalent to the difference between the actual acquisition price and the market price is conducted in accordance with separate provisions on the grounds of taxation, and thus, the position that the tax authority imposed on the opposite party does not affect the validity of the rejection of unfair act. The Plaintiff’s above assertion is without merit.)

B. From No. 6, No. 15 to No. 17 of the judgment of the court of first instance, the above facts and the plaintiff did not timely submit evidence on the conclusion and implementation of a sales contract as follows, and changed the existing assertion in accordance with the newly submitted evidence. The newly submitted evidence is highly likely to be prepared in accordance with the plaintiff's interests after the fact that the newly submitted evidence was submitted by the plaintiff. The evidence No. 1 and No. 23 of the evidence No. 21 submitted by the court of first instance, which was the date on which the date of preparation was recorded, was not the representative director, and F. Do was the representative director even if the plaintiff was the representative director.