1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On August 27, 1997, the Plaintiff purchased a forest E 21,025 square meters (hereinafter “F forest land” and divided into G, etc. after being converted into a forest land of 21,186 square meters) in the name of his/her and his/her family members, and completed the registration of transfer of ownership by purchasing the said land under the joint name of B, C, and D (hereinafter “each of the instant land”).

B. On April 23, 1998, the Plaintiff completed the registration of ownership transfer for the reason of sale in the first future with respect to each of the instant lands, and on the same day, the provisional registration for the right to claim ownership transfer was made for the reason of trade reservation in the J future with respect to one-half shares of each of the instant lands.

After that, on January 30, 1999 with respect to each of the lands of this case, the ownership transfer registration based on the provisional registration was made in the J future.

C. On May 19, 2015, the Defendant notified the J of the scheduled imposition of penalty surcharge of KRW 178,229,360 on the ground that the Plaintiff violated the Act on the Registration of Real Estate under Actual Titleholder’s Name by title trust with the J.

On June 16, 2015, the Plaintiff submitted a written opinion to the effect that the penalty surcharge is mitigated on the ground that there was an inevitable circumstance that caused the Defendant to engage in title trust, and that there was no tax evasion or avoid the restrictions under the law.

On July 7, 2015, the Defendant notified the Plaintiff on May 19, 2015 that the amount of penalty surcharge stated in the prior notice on the disposal of real estate was erroneously calculated, and that the assessment of real estate was corrected, and that the Defendant would impose penalty surcharge of KRW 239,95,760.

On July 16, 2015, the Plaintiff submitted to J a written opinion to the effect that the penalty surcharge is mitigated for the reason that the Plaintiff did not evade taxes or avoid the restrictions under the laws and regulations, on the premise that the ownership of 1/2 of each of the instant lands was nominally trusted.

E. On August 6, 2015, the Defendant imposed penalty surcharge of KRW 239,95,760 on the Plaintiff.

hereinafter referred to as "the case."