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 March 6, 2013, the Plaintiff newly built Adong building 646.74 square meters (a total of 20 households, exclusive area of 23.76 square meters, respectively; hereinafter “instant real estate”) on the ground of Jeju-si, Jeju-si, and reported acquisition tax of KRW 20,325,890, and local education tax of KRW 1,161,47,360, based on the reported value of KRW 725,924,864 on March 13, 2013 as the tax base; and paid it on March 21, 2013.

B. On October 7, 2013, the Plaintiff registered as a rental business operator for the instant real estate. On May 8, 2014, the Plaintiff asserted that acquisition tax and local education tax on the instant real estate should be exempted pursuant to Article 33 of the former Restriction of Special Local Taxation Act (amended by Act No. 12175, Jan. 1, 2014; hereinafter “Act”), and filed an application for rectification seeking refund of KRW 21,487,360 in total of the initial return, acquisition tax and local education tax paid.

C. On November 3, 2014, the Defendant: (a) decided to reduce or exempt acquisition tax on Article 33(1) of the Act (hereinafter “instant provision”) to the Plaintiff; and (b) pursuant to Article 31 of the Act, “where the Plaintiff is registered as a rental business operator within 60 days after acquisition of multi-family housing,” acquisition tax shall be reduced or exempted; (c) in order to obtain reduction or exemption of acquisition tax pursuant to the instant provision, the Plaintiff is required to register as a rental business operator within 60 days from the date of acquisition of real estate; and (d) inasmuch as the Plaintiff did not register as a rental business operator within 60 days after the construction of multi-family housing, the Plaintiff notified the Plaintiff of the decision to reject the said request for correction on the ground that the multi-family housing acquired by the Plaintiff does not constitute reduction or exemption of acquisition tax (hereinafter “instant disposition”).

On November 3, 2014, the Plaintiff appealed to the Governor of Jeju Special Self-Governing Province, but was dismissed on April 28, 2015.

[Ground of recognition] Facts without dispute, Gap evidence 1 to 4, Eul evidence 1 to 3, the purport of the whole pleadings

2. Determination;