1. Of the disposition imposing global income tax of KRW 144,168,852 imposed on the Plaintiff on April 12, 2017, penalty tax of KRW 60.

1. Details of the disposition;

A. On December 28, 2007, the Plaintiff: (a) concluded a sales contract with the head of the white industry development (hereinafter “the instant sales contract”); (b) to sell KRW 3,144,90,000 (hereinafter “the instant down payment”); and (c) to sell KRW 314,490,000 (hereinafter “the instant down payment”) the remainder of the payment, 2,830,410,000,000 for the instant down payment to the head of the white industry development (hereinafter “the instant down payment”); and (d) to receive KRW 2,830,410,000 from March 10, 2009, the Plaintiff agreed to receive the payment of KRW 2,830,410,000,00 for the land transaction permission zone under the National Land Planning and Utilization Act (hereinafter “National Land Planning Act”).

B. The Plaintiff notified three times to perform the remainder on the outstanding payment date, and notified the cancellation of the instant sales contract on June 17, 2009.

In the instant sales contract, the Plaintiff may rescind the instant sales contract where the obligation to pay the purchase price is overdue for not less than three months due to a cause attributable to the development of the white industry, and in such a case, the contract deposit already paid shall belong to the Plaintiff.

(Evidence 1, section 6(4)(c).

On May 31, 201, the instant land was released from the designation of the land transaction permission zone.

On May 31, 201, the date of the cancellation of the land transaction permission zone, the Defendant: (a) deemed that the remaining amount of KRW 284,490,000 remaining after deducting necessary expenses corresponding to the penalty was reverted to the Plaintiff on the ground that the contract deposit 314,490,000 was reverted to penalty; and (b) imposed and notified the Plaintiff on April 19, 2017 as global income tax of KRW 83,235,35,335, additional tax of KRW 60,93,517 (hereinafter “instant disposition”).

E. The Plaintiff appealed and filed an appeal with the Tax Tribunal on June 28, 2017, but was dismissed on September 20, 2017.

[Ground of Recognition] Facts without dispute, Gap evidence 1 to 6, and Eul 1.