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 October 12, 201, Ecex entered into a contract to sell a site with regard to the land for a 11,610 square meters of land for a 34 Blux industrial complex in Gangseo-gu Busan Metropolitan City (which is determined as 11,593.7 square meters of land in Gangseo-gu, Busan Metropolitan City; hereinafter “instant land”).

The Plaintiff’s merger of Escp Co., Ltd., and on January 24, 2014, the buyer of the above site sales contract changed from Escp to the Plaintiff, and the Plaintiff completed the registration of ownership transfer on September 29, 2014.

B. On June 12, 2014, the Plaintiff applied for the disposition of the instant land to the head of the Busan High Sea Free Economic Zone Authority, which is an industrial complex management authority for the Mountainous Districts, but revoked the application on March 31, 2015.

On December 2, 2015, the Plaintiff filed an application for the disposal of the instant land again with the head of the Busan High Free Economic Zone Authority, and the head of the Busan High Free Economic Zone Authority selected Tti Co., Ltd. as an enterprise eligible for occupancy as a result of the process of selling the said land.

On March 11, 2016, the Plaintiff entered into a sales contract for the instant land with Ethymat Co., Ltd., and completed the registration of ownership transfer on the instant land in the future of Ethymat Co., Ltd. on April 18, 2016.

C. Under Article 78(5)1 of the former Restriction of Special Local Taxation Act (amended by Act No. 12955, Dec. 31, 2014; hereinafter the same) on the ground that the Plaintiff sold the instant land to a third party without any justifiable ground within three years from the date of acquisition thereof, the Defendant imposed and notified the Plaintiff of KRW 17,961,390 of property tax for the year 2014, which was reduced or exempted to the Plaintiff on August 5, 2016 and KRW 3,592,270 of local education tax and KRW 18,375,280 of property tax for the year 2015 and KRW 3,675,050 of local education tax and KRW 18,675,050 of local education

(hereinafter “instant disposition”) D.

On August 16, 2016, the Plaintiff is dissatisfied with the Central Administrative Appeals Commission.