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

A. The Plaintiff, a quasi-residential area under the National Land Planning and Utilization Act (hereinafter “National Land Planning Act”), established and operated a substation with a total floor area of 2,655.36 square meters on the ground of 700 square meters on September 29, 1989, Nowon-gu, Seoul Special Metropolitan City, Nowon-gu, for the stable supply of electricity in the offset Dong area (hereinafter “instant substation”).

B. From the date of installation of the instant substation to the date of 2016, the Defendant deemed the instant substation as “other buildings” under Article 111(1)2(c) of the Local Tax Act and imposed property tax, etc. on the instant substation by applying the corresponding tax rate (2.5/1,000 from 2012 to 2016, which is at issue in the instant case).

C. On February 10, 2017, the Defendant: (a) deemed the instant substation as a “factory building” located in a residential area; and (b) applied Article 111(1)2(b) of the Local Tax Act to the Plaintiff, subject to Article 111(1)2(b) of the Local Tax Act, imposed property tax and local education tax additionally on the Plaintiff,

(hereinafter “Disposition in this case”). 【No dispute over the grounds for recognition”, Gap’s evidence Nos. 1, 2, and Eul’s evidence Nos. 2 and 3, and the purport of the whole pleadings

2. To make entries in the attached statutes concerned;

3. The plaintiff's assertion

A. In accordance with the provisions of local tax law, a substation is excluded from “factory buildings” unless property tax is levied heavy pursuant to Article 111, etc. of the Local Tax Act.

However, Article 111 (1) of the Local Tax Act is distinguished from Article 111 (2) of the same Act, which clearly states whether or not the local tax is excessive by using the expression "50/100" and "50/100".

Therefore, Article 111(1)2(b) of the Local Tax Act cannot be interpreted as “in cases of heavy taxation of property tax” in which the tax rate is applied, and accordingly, the transformation station in this case does not constitute a case of heavy taxation of property tax.