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 July 22, 1994, the Plaintiff owned 3,174 square meters (hereinafter “instant farmland”) as a donation from his father C, and transferred 370,000,000 won on April 15, 2013.

B. On June 27, 2013, the Plaintiff applied for reduction or exemption of capital gains tax on the farmland of this case to the Defendant under Article 69 of the former Restriction of Special Taxation Act (amended by Act No. 13560, Dec. 15, 2015; hereinafter the same).

C. The defendant conducted an investigation of capital gains tax against the plaintiff, on the ground that the plaintiff has separate earned income and confirmed the fact that he had made the farmland in this case by proxy to another person, the plaintiff is required to reduce capital gains tax for eight years

In December 1, 2015, the Plaintiff corrected and notified the Plaintiff of KRW 82,720,510 of the transfer income tax for the year 2013.

(hereinafter “instant disposition”) D.

The Plaintiff filed an objection on January 6, 2016, but was dismissed. On April 20, 2016, the Plaintiff filed an appeal with the Commissioner of the National Tax Service for adjudication on April 20, 2016, but was dismissed on June 20, 2016.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2, Eul evidence 1 (including branch numbers; hereinafter the same shall apply), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion was possessed for about 18 years and seven months until the transfer of the farmland of this case, and cultivated crops by inserting more than 1/2 of the direct labor force while residing in and residing in the farmland of this case or adjacent areas. As such, the Plaintiff was self-employed for not less than eight years from each farmland of this case, and thus, the need for reduction of capital gains tax under Article 69 of the former Restriction of Special Taxation

Although it is reasonable to deem that the defendant satisfied the case, the defendant's disposition of this case is unlawful on a different premise.

(b) as shown in the attached Form of the relevant statutes.

C. (1) The legislative purpose of the Act on the Reduction and Exemption of Transfer Income Tax for Self-Cultivating Farmland is Article 69 of the former Restriction of Special Taxation Act.