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 June 11, 2004, the Plaintiff, as a church under B’s general assembly as an incorporated foundation, owned the 3rd floor of Gangnam-gu Seoul Metropolitan Government D (hereinafter “instant real estate”) by donation from C, which is a standing tree, and transferred the same to E on May 30, 201, and did not report the transfer income tax.

B. On January 13, 2014, the Defendant rendered the instant disposition that determined and notified KRW 61,385,800 to the Plaintiff on January 13, 2014, by deeming that a religious organization deemed an individual under the Framework Act on National Taxes transfers real estate as a taxable object of capital gains tax.

C. The Plaintiff appealed and filed an appeal with the Tax Tribunal on August 18, 2014, but was dismissed on November 24, 2014.

[Ground of recognition] Facts without dispute, entry of evidence No. 1, purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff asserted that the Plaintiff was acting as a nonprofit corporation from the time when the Plaintiff was registered as a business operator on December 16, 1994, and that from around December 2012, 2012, the Plaintiff did not obtain the approval of the “organization deemed a corporation” as it did not hear any explanation about tax benefits from the Defendant, and was an organization deemed a corporation. Meanwhile, the Plaintiff obtained the approval of the “organization deemed a corporation” on February 14, 2014, so the transfer profit of the instant real estate transferred on May 30, 201 can be included in the profit and loss of the corporation.

Therefore, the Plaintiff is a “organization Considered as a corporation,” and there is no capital gains tax liability, and as a non-profit domestic corporation, there is no corporate tax liability.

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

(c) Article 13 (2) of the Framework Act on National Taxes shall apply to an unincorporated organization, other than an association, foundation, or other organization deemed a juristic person under paragraph (1), which meets all the following requirements, and for which an application is filed by a representative or manager to the head of the competent tax office for approval, and this Act and other tax

In such cases, the relevant association, foundation, or other organization.