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 September 4, 2003, the Plaintiff owned 673 square meters (hereinafter “the instant farmland”) of the land of this case with the donation from Seogdong-gu, Young-gu, Seog-si C on January 31, 2012, and reported to D on March 24, 2012 that the entire amount of capital gains tax was reduced on the ground that the instant farmland constitutes self-farmland for eight years, while transferring it to D on January 31, 2012, and filing a preliminary return for the transfer income tax reverted to the Defendant on March 24,

B. On December 1, 2012, the Defendant imposed and collected capital gains tax of KRW 209,066,410 (including additional tax) on the Plaintiff in December 1, 2012, on the ground that the Plaintiff did not directly cultivate the farmland of this case for at least eight (8) years after conducting a field investigation on the farmland of this case.

C. On February 28, 2013, the Plaintiff appealed to the Board of Audit and Inspection, but was dismissed on February 6, 2014.

[Reasons for Recognition] Unsatisfy, Gap evidence 2, Eul evidence 7

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion had resided in the vicinity of the farmland, and had constantly cultivated the farmland of this case by planting fruit trees, such as ornamental trees, bamboo trees, and bamboo bamboo trees. The Plaintiff cultivated crops such as spawn and spawn, etc. on the farmland of this case on September 4, 2003, such as spawn and spathn, inasmuch as it had not been planted, it constitutes reduction in capital gains tax on self-employed farmland pursuant to Article 69(1) of the Restriction of Special Taxation Act.

B. Article 69(1) of the Restriction of Special Taxation Act provides that the tax amount equivalent to 100/100 of capital gains tax shall be reduced on the income accruing from the transfer of land prescribed by the Presidential Decree, which has been cultivated directly by the resident residing in the location of the farmland for not less than eight years by the resident prescribed by the Presidential Decree, and as to the direct cultivation of farmland, the taxpayer has the burden of proof.

Pursuant to the purport of the whole statement and pleading of No. 4-1, 2, and 3.