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 December 26, 197, the Plaintiff acquired respectively on the ground of the inheritance of 2,885 square meters in Seo-gu B, Seo-gu, Seopo-gu, Seopo-gu on November 3, 2000 and transferred the same to D on August 6, 2013 (hereinafter “instant transfer”).

B. On October 31, 2014, the Plaintiff reported a transfer income tax on the transfer of each of the instant lands, and filed an application for reduction of KRW 200 million among KRW 327,371,561 of the calculated tax amount, on the ground that each of the instant lands was self-covered for at least eight years, and paid the remainder KRW 127,371,561.

C. On November 13, 2014, the Defendant, on the ground that each of the instant lands was not farmland as of the date of the instant transfer, excluded the reduction or exemption of capital gains tax on self-Cultivating farmland, and issued a correction notice (hereinafter “instant disposition”) of capital gains tax of KRW 222,96,960 (including additional tax of KRW 22,96,960) accrued in 2013.

On November 25, 2014, the Plaintiff filed an appeal on the instant disposition, but the appeal was dismissed on March 18, 2015.

【Ground of recognition】 The fact that there has been no dispute, Gap Nos. 1, 2, Eul Nos. 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) Article 66(5)2 of the former Enforcement Decree of the Restriction of Special Taxation Act (amended by Presidential Decree No. 26070, Feb. 3, 2015) to which the capital gains tax reduction and exemption provision applies (hereinafter “instant reduction and exemption provision”).

In the case where the relevant farmland is designated as a land to be reserved for replotting other than the farmland and it is not cultivated by the implementation of the construction works to create the land after the designation of the land to be reserved for replotting within three years from the date of the designation of the land to be reserved for replotting: it shall be deemed as the farmland standard as of

In most urban development projects implemented by replotting, land creation works, along with the excavation of buried cultural heritage, shall be made prior to the designation of reserved land.