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 November 2, 2007, the Plaintiff completed the registration of ownership transfer on October 23, 2007 with respect to the aggregate of 13,736 square meters of land (hereinafter “instant farmland”) other than C, which was the father B, and nine parcels (hereinafter “instant farmland”).

B. On November 22, 2007, the Plaintiff filed a return on gift tax reduction or exemption pursuant to Article 71 of the former Restriction of Special Taxation Act (amended by Act No. 9272, Dec. 26, 2008; hereinafter the same) on the ground that the Plaintiff, as a farming child, was donated the farmland of this case from the said farmer B, a self-employed farmer.

C. From February 22, 2016 to March 22, 2016, the Defendant issued an on-site verification for the follow-up management of farmland subject to gift tax reduction and exemption, and subsequently, on the ground that the Plaintiff cannot be deemed to have engaged in direct farming, such as the occurrence of high-amount revenue for at least three consecutive years retroactively from the date of donation of the instant farmland, and thus, was not a farming child, the Defendant corrected and notified the Plaintiff of KRW 197,56,710, gift tax around June 3, 2016.

(hereinafter referred to as the "disposition of this case"). 【No dispute exists, Gap evidence Nos. 1 through 4, 17, and 18 (including the number with each number; hereinafter the same shall apply), Eul evidence Nos. 1, 2, and the purport of the whole pleadings.

2. Whether the instant disposition is lawful

A. As to the Defendant’s assertion that the instant disposition is lawful on the grounds of the grounds of the disposition and the relevant statutes, the Plaintiff asserted that the Plaintiff is a farming child under the former Restriction of Special Taxation Act, such as residing in the farmland location and actually cultivating the farmland, and that the instant disposition based on a different premise is unlawful.

(b) as shown in the attached Form of the relevant statutes;

(c) Determination 1) Article 71(1) of the former Restriction of Special Taxation Act (amended by the Presidential Decree No. 1) provides that a resident prescribed by the Presidential Decree, who resides in the seat of farmland and directly cultivates farmland, shall be a lineal descendant prescribed by the Presidential Decree