1. The Defendant’s rejection disposition against each of the Plaintiffs on March 27, 2013 is revoked.

2...

1. Details of the disposition;

A. On February 17, 1997, the Plaintiffs: (a) transferred the instant land on February 18, 201 after completing the registration of ownership transfer based on inheritance due to a consultation division with respect to 1/2 shares among the land (hereinafter “instant land”); and (b) transferred the instant land on February 18, 201; (c) the acquisition value is KRW 300,000,000, the officially assessed individual land price (standard market price 1,300,000, 128,895,000, and the transfer income amount is KRW 118,723,500,000; and (d) the transfer income is KRW 118,723,

3. 7.20: (a) returned and paid KRW 25,778,225, respectively, of the capital gains tax reverted to year 2011.

B. After that, on February 22, 2013, the Plaintiffs filed a request for correction to the effect that the Plaintiffs would refund KRW 5,587,103 on the ground that the date of acquisition of the instant land falls under February 17, 1997, by applying the officially assessed individual land price (1,530,000 square meters) in 197. However, the Defendant filed a request for correction to the effect that the refund would be made.

3. 27. Each rejected the Plaintiffs’ request for correction.

(hereinafter “each disposition of this case”). (c)

On April 4, 2013, the Plaintiffs were dissatisfied with each of the instant dispositions and filed an appeal with the Tax Tribunal. However, the Plaintiffs were dismissed on December 30, 2013.

[Ground of recognition] Facts without dispute, entries in Gap's evidence 1 through 6 (including provisional number), and the purport of whole pleadings

2. Whether each of the dispositions of this case is legitimate

A. The plaintiffs asserted that when the acquisition value is deducted from the necessary expenses for the return and payment of the transfer income tax of this case, the acquisition value was calculated by applying the standard market price in February 17, 1997, which was the time of acquisition of the land of this case, and the acquisition value was calculated by applying the standard market price in 1996, which was the immediately preceding year, pursuant to Article 164(3) of the Enforcement Decree of the Income Tax Act.

However, if the standard market price of the year is not publicly announced on the date of acquisition or transfer, there is an exceptional provision allowing the application of the standard market price of the immediately preceding year, and if the standard market price of the year of acquisition can be known at the time of return and payment of transfer income tax after the date.