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 June 2, 1995, the Plaintiff acquired B 671 square meters, C 539 square meters, D 661 square meters, E 539 square meters, and F 430 square meters (hereinafter the above five parcels collectively referred to as “instant land”). On June 7, 2010, the Plaintiff transferred the instant land on June 7, 201.

B. The Plaintiff asserted that the instant land was cultivated directly for at least eight years upon filing a preliminary return of capital gains tax, and the Defendant applied for reduction or exemption of capital gains tax. However, the Defendant conducted an investigation into the instant land, and deemed that the Plaintiff did not cultivate at least half of the farming work from the instant land with his own labor, and thus, did not apply the capital gains tax reduction or exemption provisions on self-employed farmland, and on August 11, 2014, notified the Plaintiff of KRW 194,092,850 for the capital gains tax corresponding to the year 2010 (hereinafter “instant disposition”).

C. The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on September 25, 2014, but was dismissed on February 23, 2015.

[Ground of recognition] Facts without dispute, Gap evidence 6, Eul evidence 1, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. Since the Plaintiff’s assertion directly cultivated the instant land for not less than eight years after acquiring the instant land, the instant disposition denying the instant land constitutes reduction and exemption of self-arable farmland is unlawful.

(b) Entry in the attached Form of relevant Acts and subordinate statutes;

C. 1) Article 69(1) of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010); Article 66(1) and (13) of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 23590, Feb. 2, 2012) of the same Act (amended by Presidential Decree No. 23590, Feb. 2, 2012) in order to be granted reduction or exemption of capital gains tax, the relevant farmland must be cultivated directly by residing in Si/Gun/Gu where the relevant farmland is located, Si/Gun/Gu adjacent to the relevant farmland, or Si/Gun/Gu adjacent to the relevant farmland, or