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 May 4, 1987, the Plaintiff purchased each share of 873m2 and 1/4m2 in Ulsan-gu, Ulsan-gu and C 549m2, and completed the registration of ownership transfer. On May 1, 1989, the said land was designated as a land substitution under a land substitution project. On February 10, 1992, the Plaintiff acquired the ownership of 1/4 share of the said D land (hereinafter “instant land”).

B. On July 1, 2013, the Plaintiff transferred the instant land by reason of sale on April 4, 2013 to the Defendant on the preliminary return of the tax base of capital gains tax under Article 105(1) of the Income Tax Act, the transfer value shall be KRW 2,800,000,00, and the acquisition value shall be determined by taking into account the formula prescribed in Article 164(4) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 26067, Feb. 3, 2015; hereinafter “former Enforcement Decree”) (hereinafter “instant formula”), the acquisition value of the instant land shall be determined by applying the standard market price of 2,430,929,956, which is at the time of acquisition on January 1, 1989; the acquisition value of the instant land shall be determined by applying the standard market price of 10,422,575, which is at the time of acquisition of the instant land at the time of 1900.4.