The plaintiff's claim is dismissed.

Litigation costs shall be borne by the plaintiff.

1. Details of the disposition;

A. On May 1, 200, the Plaintiff was an organization established for missionary activities and received a notification of approval from the Defendant (the head of a military tax office) by filing an application for approval of an organization deemed a corporation under Article 13(2) of the Framework Act on National Taxes (a non-profit domestic corporation). On May 12, 2000, the Plaintiff received business registration number (C and the identification number of an organization deemed a corporation) upon business registration.

B. On November 12, 2002, the Plaintiff purchased D and E land in the Gunsan City, purchased F land on June 5, 2003 (hereinafter collectively referred to as “instant church site”) and completed registration of the ownership by completing the construction work on August 22, 2003 and completing the registration of the ownership of the instant church building on March 3, 2004.

C. On the other hand, on September 5, 2003, at the request of the representative of the plaintiff, the organization's identification number (C) to be considered as a corporation was reported for business closure, and the identification number (G and business registration number of an organization to be considered as an individual) under the Income Tax Act was given to the plaintiff on the same day.

On December 27, 2011, the Plaintiff transferred the instant church site and the instant church building (hereinafter collectively referred to as “instant real estate”) to the I Regional Housing Association located in H KRW 1,405,00,000.

E. At the time of the transfer of the instant real estate, the Defendant: (a) deemed the Plaintiff as a resident under the Income Tax Act on the ground that the Plaintiff does not constitute “organization deemed a corporation” under Article 13(2) of the Framework Act on National Taxes; and (b) determined and notified the Plaintiff of KRW 92,186,380 as the transfer income tax reverted to the year 201 concerning the disposal of the instant real estate on January

(f) On March 31, 2014, the Plaintiff filed an objection with the Defendant and filed an appeal with the Tax Tribunal on May 23, 2014. However, the claim was dismissed on October 17, 2014, and on December 26, 2014.