1. All of the instant lawsuits are dismissed.

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

1. Details of the disposition;

A. On June 7, 2011, the Plaintiff completed registration of initial ownership in relation to Nos. 201, 302, and 401 among multi-households located in Gwangju-si B and C.

The plaintiff 2012

3. Although each of the above houses was transferred from March 15 to March 22, 2012, the relevant comprehensive income tax was not reported.

B. On June 10, 2016, the Defendant imposed a global income tax of KRW 39,449,553 on the transfer margin of each real estate in the year 2012 (hereinafter “instant global income tax disposition”) and imposed KRW 3,848,820 on the Plaintiff pursuant to Article 93(2) of the former Local Tax Act (Amended by Act No. 11690, Mar. 23, 2013).

(2) Each of the items of evidence No. 8-2, evidence No. 1, 2, and 3, and evidence No. 9-1 and No. 9-2, and the purport of the whole pleadings and arguments, shall be deemed to have been imposed by the Gwangju Metropolitan City pursuant to Article 93(5) of the former Local Tax Act.

2. Determination on the legitimacy of the instant lawsuit

A. As to the claim seeking revocation of the instant global income tax imposition disposition, the Defendant asserted that the part seeking revocation of the instant global income tax imposition disposition among the instant lawsuit is unlawful, as it was filed without going through lawful procedures.

Article 56 (2) of the Framework Act on National Taxes provides that any administrative litigation against any illegal tax disposition shall not be filed without going through a request for examination or adjudgment under the Framework Act on National Taxes and a decision thereon, and Articles 61 (1) and 68 (1) provide that any relevant disposition shall be filed within 90 days from the date (if a notice of disposition is received, the date of its receipt) on which the relevant disposition is known.

Therefore, the administrative litigation seeking the revocation of tax disposition, which was filed without going through the aforementioned legitimate procedure, is unlawful.

As to the instant case, the case is examined.