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

A. On July 22, 2013, the Plaintiff completed business registration under the Housing Construction and Sales Business Act jointly with B, and started a multi-family housing of eight households (hereinafter “instant multi-family housing”) on August 8, 2013, on the land of Jung-gu Government-si, the Government-si (hereinafter “instant multi-family housing”) and conducted a business selling the multi-family housing after obtaining approval for use on April 28, 2014 (hereinafter “instant business”).

B. On May 29, 2015, the Plaintiff calculated the business income amount of the instant case for 2014 by applying the simple expense rate, on the premise that the Plaintiff, in 2013, sold by-products of the previous building and obtained a revenue amount of less than 36 million won from the sale of by-products of the previous building in the taxable period immediately preceding 2014, which was the taxable period of 2014, and filed a return on and pay the global income tax amount of 38,482,035 (including additional tax of 2,238,492) by applying the special tax reduction and exemption for the construction business from the tax amount calculated accordingly.

C. The Seoul Regional Tax Office: (a) the Defendant: (b) the date of commencement of the instant business ought to be deemed to be 2014 years from the new construction and sale of the instant apartment; (c) thus, the amount of income belonging to 2014 ought to be calculated by applying standard expense rate; and (b) notified the Defendant of taxation data that the application of special tax reduction and exemption for small and medium enterprises should be denied

Accordingly, on August 11, 2017, the Defendant rendered the instant disposition with the content that, by applying standard expense rate to the Plaintiff, the Defendant estimated the amount of income attributed to year 2014 and deducted the amount of tax already paid from the amount of tax calculated accordingly, the Defendant issued a revised notice of KRW 130,630,200 as global income tax for the year 2014.

【Ground of recognition】 The fact that there has been no dispute, Gap's 1 through 3, Eul's 1 through 3, the purport of the whole pleadings and arguments

2. Whether the instant disposition is lawful

A. The plaintiff asserts that the disposition of this case is unlawful for the following reasons.

1 The Plaintiff newly constructs the instant collective housing in 2013.