1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasons why the court of the first instance should explain are as follows: (a) the reasons why the plaintiff is required to refer to the argument that the court of the first instance emphasizes in particular or re-convened is identical to the reasons of the first instance judgment, except for the addition under the following: (b) Article 8(2) of the Administrative Litigation Act; and

2. Judgment on the plaintiff's assertion

A. The Plaintiff’s assertion 1) The meaning of the abbreviationd language used by Nonparty’s inheritors for the primary purport of claim is the same as that of the first instance judgment. Although the Plaintiff paid to Nonparty’s heir for consideration and acquired the instant share at a cost, it cannot be confirmed at the present time. As such, the acquisition price for conversion under Article 114(7) of the Income Tax Act and Article 176-2 of the Enforcement Decree of the Income Tax Act should be considered as the acquisition price for preliminary claim. 2) The Plaintiff’s assertion as to the instant share acquired upon consultation on division of inherited property with Nonparty’s heir on May 16, 1994, since the Plaintiff acquired the instant share upon the agreement on division of inherited property with respect to the instant real estate between Nonparty’s heir and Nonparty’s heir, the Plaintiff’

B. 1) Determination 1) Comprehensively taking account of the overall purport of the arguments adopted on the grounds of the judgment of the court of first instance, cited by this decision as to the argument as to the primary purport of the claim, the following circumstances, namely, ① Nonparty’s heir did not report transfer income tax, and there was no other evidence to deem that the Plaintiff paid the purchase price of the instant real estate to the Nonparty’s heir. ② The Plaintiff was able to prepare and present a receipt for acquiring the instant real estate at the time of the Defendant’s on-site investigation of transfer income tax (No. 3). ③ The Plaintiff continued financial transactions with Nonparty’s heir before or after the completion of registration under the name of the Plaintiff’s sole owner of the instant real estate.