1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. Details of the disposition;

A. The forest of this case is not more than 13,616§³ of forest land B (Gu parcel number) in Tae-gun, Chungcheongnam-gun (Gu) (hereinafter “instant forest”).

B As to May 20, 2003, the sale on May 20, 200 (hereinafter referred to as “first sale”). On the same day, G had completed the registration of ownership transfer in the Plaintiff’s future on the same day, and the same year.

8. On the 23th of the same month on the 18th day, the registration of ownership transfer of 1/2 shares from the Plaintiff was completed on the 23th day of the same month.

B. On August 26, 2003, the Plaintiff filed a preliminary return of KRW 564,00,000 for the transfer value of the forest of this case with the acquisition value of KRW 30 million and KRW 26 million for the Defendant.

C. On March 6, 2014, the Defendant imposed upon the Plaintiff an increase of KRW 132,629,910 for the transfer value of the instant forest, KRW 26 million for the acquisition value, KRW 170,564,00 for the tax base of KRW 170,564,00, and KRW 132,629,910 for the transfer income tax (including additional tax) for the year 2003, but again imposed a corrective disposition that reduces the acquisition value of the instant forest by KRW 49,00,000 for the acquisition value of the instant forest as of January 26, 2017.

AB made it.

[Reasons for Recognition] Facts without dispute, Gap evidence Nos. 1 through 3, Eul evidence Nos. 3, 4, 8 (including branch numbers, if any; hereinafter the same shall apply), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The gist of the Plaintiff’s assertion is that the title trustee lent the ownership of the instant forest upon the request of E, and the income accrued from the transfer of the instant forest was entirely attributed to E, the title truster.

Therefore, the instant disposition based on the premise that the Plaintiff is the true owner is unlawful against the principle of substantial taxation.

Even if the title trust relationship is not recognized, the value of the forest of this case acquired by the Plaintiff was KRW 80 million or KRW 90 million, but the Defendant rendered the instant disposition.