1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

The first instance court.

1. The reasons for the court's explanation concerning this case are as follows: (a) the statement of evidence Nos. 2 and 3 (including the paper number) in each of the evidence Nos. 2 and 3 (including the paper number) which the plaintiff is insufficient to recognize the actual transaction price for purchasing the land of this case from B; and (b) the testimony of witness E of the party hearing witness of the court of first instance is rejected; and (c) the judgment on the plaintiff's argument in the trial is as stated in the part of the reasons for the judgment of the court of first instance, except for addition of the judgment below as to the plaintiff's argument

2. Additional determination

A. As long as the Defendant asserted that the acquisition value reported by the Plaintiff is different from the fact, the Defendant shall confirm the actual transaction value at the time of acquisition in accordance with the purport of the Supreme Court Decision 2010Du27592 Decided February 9, 2012 and calculate the transfer income tax by deeming the confirmed value as the acquisition value. If the actual transaction value at the time of the Plaintiff’s acquisition is not verified, the transfer income tax shall be calculated based on the standard market price at the time of acquisition of the instant land pursuant to Articles 96(1) and 97(1)1(a) of the former Income Tax Act (amended by Act No. 7837, Dec. 21, 2005). The instant disposition was erroneous by calculating the acquisition value of the instant

B. In the above decision of the Supreme Court Decision 2010Du27592, where the returned value is confirmed as the actual transaction value by the transferor of the asset under Article 94(1)1 and 2 of the former Income Tax Act (amended by Act No. 7837 of Dec. 31, 2005; hereinafter “former Income Tax Act”), the transfer income amount shall be calculated based on the actual transfer and acquisition value, but where the reported value is not confirmed as the actual transaction value, the transfer income amount shall be determined based on the actual transfer and acquisition value, but Article 114 of the same Act shall be confirmed based on the actual transaction value different from the reported value by the