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 2007, the Plaintiff transferred to B the right to hot spring development of the Gyeongcheon-gun C Forest (hereinafter “the instant forest”) and paid the price of KRW 1 billion (hereinafter “instant income”), but did not file a comprehensive income tax return with the tax authority.

B. On September 4, 2013, the Defendant notified the Plaintiff of the correction of the global income tax of KRW 103,488,330 (additional tax of KRW 310,460), which reverts to the year 2007, after deducting 80% of the instant income amount from the necessary expenses, with the amount of KRW 200 million.

[Ground of recognition] The facts without dispute, Gap evidence Nos. 1 through 4, Eul evidence Nos. 1, and the purport of the whole pleadings / [founded statutes] Article 21 (Other Incomes) of the former Income Tax Act (wholly amended by Act No. 10408, Dec. 27, 2010) (amended by Act No. 10408, Dec. 27, 2010) 1 Other incomes are as follows:

7. With respect to other incomes falling under any of the following subparagraphs, with respect to such other incomes as are received in consideration of the transfer or lease of mining rights, fishing rights, industrial property rights, industrial information, industrial secrets, trademark rights, business rights (including the right to lease a store prescribed by Presidential Decree), rights incidental to permission to collect earth, sand, and rock, rights to develop and use underground water, and other assets or rights similar thereto, and the price therefor, an amount equivalent to 80/100 of the amount received by a resident shall be necessary expenses, with respect to such other incomes as prescribed in the following subparagraphs:

4. Other incomes under Article 21 (1) 7 of the Act, for which the necessary expenses are not confirmed or are short of 80/100 of revenue amount; and

2. Whether the instant disposition is lawful

A. The Plaintiff alleged that the Plaintiff contracted the instant hot spring development project to D with the cost of construction KRW 500 million. The instant hot spring development project is the instant hot spring development project.