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

가. 원고는 1995. 1. 23.부터 서울 ★★★구 ☆☆☆동 492-4에서 골프연습장업을 영위하여 오다가, 2002. 6. 1. 그 업종을 부동산매매업으로 변경하고 위 지상에 오피스텔을 신축하여 2004년 및 2005년에 위 오피스텔을 분양하였다.

B. The Plaintiff deducted the amount of special long-term holding deduction amounting to KRW 2,464,676,317 in accordance with each of the provisions of Articles 69 (amended by Act No. 8144, Dec. 30, 2006; hereinafter the same) and 107 (1) of the Income Tax Act and Article 128 (1) of the Enforcement Decree of the same Act, but did not deduct the amount of special long-term holding deduction when filing the final return of global income tax.

C. On May 28, 2007, with respect to a real estate sales businessman for the defendant, the plaintiff applied the special long-term holding deduction at the time of the preliminary return of profit margin, and argued that the special long-term holding deduction at the time of the final return of global income tax is unreasonable, and the plaintiff applied the special long-term holding deduction at the time of the final return of global income tax, and filed a request for correction for each refund of global income tax for 2004 and 2005 as stated in the purport of the claim. However, on July 25, 2007, the defendant rejected the plaintiff's request for correction on the ground that the special long-term holding deduction at the time of the final

[Ground of recognition] Unsatisfy, Gap evidence 1-1-16, Gap evidence 2-1, 2-2, and Gap evidence 3

2. Whether the rejection disposition of this case is legitimate

A. The plaintiff's assertion

In the case of real estate sales brokers, even though it is unreasonable to exclude special deduction for long-term holding which was applied at the time of filing the final return of global income tax, the Defendant erred by misapprehending the legal principles on special deduction for long-term holding, thereby rejecting the Plaintiff’s request for correction. Therefore, the Defendant’s refusal disposition of this case

(b) Related statutes;

It is the same as the entry of the attached statutes.

C. Determination

1) In full view of the following circumstances, each provision of the relevant Acts and subordinate statutes provides that the Defendant’s refusal disposition, which reported that the special deduction for long-term holding against the Plaintiff, a real estate sales businessman, is not applicable at the time of filing the final return of global income tax, is lawful as it is in accordance with the relevant Acts and subordinate statutes.

A) In light of the fact that the profit margin preliminary return and voluntary payment system of a real estate broker under Article 69 of the Income Tax Act is established in order to secure tax claims at an early stage and prevent the accumulation of tax burdens, which are similar to the interim prepayment system of global income tax, and that a real estate broker must make a final return of global income tax even in cases where the above preliminary return of profit margin was made, even though Articles 69 and 107(1) of the Income Tax Act and Article 128(1) of the Enforcement Decree of the same Act provide that the special deduction for long-term holding shall be applied at the time of the preliminary return of profit margin of a real estate broker, it cannot be deemed that the said preliminary return of profit

B) The global income tax is governed by the principle of the fixed-term taxation, and the total amount of global income generated during the pertinent taxable period is determined by calculating the tax base and the amount of the tax and the specific tax liability to be comprehensively reported is determined. There is no provision to apply the special long-term holding deduction at the

2) Accordingly, there is no reason for the senior secretary-general in e.g., another electrical system.

3. Conclusion

The plaintiff's claim is dismissed because there is no reason for the plaintiff's claim.