양도소득세부과처분취소
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 December 31, 2003, the Plaintiff acquired B 1,771 square meters and C B 2,354 square meters prior to Sungsung-si on December 31, 2003, and the said two land became a land site B 4,125 square meters prior to subdivision (hereinafter “land category change and merger”) after land category change and merger on December 4, 2005.
B. On October 31, 2002, the Plaintiff newly constructed two factory buildings (the first building with the total floor area of 755.23 square meters, the second building area of 788.5 square meters; hereinafter the same shall apply) on the land before the subdivision, with the construction permission for the construction of the first building and the second building with the total floor area of 755.23 square meters, and the second building "the second building of this case", and with the approval for the use of each building of this case on December 8, 2005.
C. The first building of this case is located on the instant D land, and the building of this case is located on the instant E and F land, the building of this case is located on the instant land, where the instant building is located on the instant land, and the building of this case is located on the instant E and F land.
On March 29, 2009, the Plaintiff transferred the instant land and the instant building No. 12 square meters of G factory site to H in Sungsung. Upon filing a transfer income tax report, the Plaintiff filed a total of 304,406,669 won, total of 489,250,528 won, transfer value, and total of 254,685,886 won (total of 520,591,400 won, total construction cost, etc. used to newly construct each of the instant buildings reported by the Plaintiff x total of 520,591,40 won x total of construction cost, etc. used to construct each of the instant buildings x 755.23 square meters of total floor area of each of the instant buildings / total of 1,543 square meters of total floor area of each of the instant buildings / transfer value was reported as KRW 260,749,4722 won, and transfer value was reported as KRW 260,747472.
E. On April 24, 2012, the Plaintiff transferred the instant E and F land, and the instant building and machinery of the instant building No. 2 on its ground to ELS Co., Ltd., and reported the transfer income tax thereon.