1. The defendant's appeal is dismissed.

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

Purport of claim and appeal

1...

1. The reasoning of the judgment of the court of first instance cited the same reasoning as that of the judgment of the court of first instance, except for adding the following matters to the reasoning of the judgment of the court of first instance, and thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the

Part 7, paragraph 11, the following shall be added:

"4 The defendant asserts that the transfer value of the sales contract for the land and buildings of this case includes the value of business rights, and that the value of the land and buildings is unclear, so the above sales contract constitutes a case where the distinction between the value of the land and buildings is unclear.

However, there is no evidence to prove that the data submitted by the defendant contains the value of a separate business right that can not be included in the value of land and building in the transfer value of the above sales contract.

In addition, the defendant's disposition of this case was made on the premise that the transfer value of the above sales contract is the total value of the land and the building.

“”

2. In conclusion, the plaintiff's claim of this case is reasonable, and the judgment of the court of first instance is just, and the defendant's appeal is dismissed. It is so decided as per Disposition.