All of the plaintiffs' claims are dismissed.

The costs of lawsuit shall be borne by the plaintiffs.

1. Details of the disposition;

A. On July 4, 2016, the Plaintiffs jointly acquired ownership of land (hereinafter “instant land”). On October 25, 2016, the Plaintiffs newly built and sold a main complex building with the size of 14th above the ground of the instant land on the instant land, on August 31, 2017, after having registered the business for the development and supply of non-residential buildings and the construction of a residential building.

B. The Plaintiffs estimated the amount of income of KRW 19,500,000 of the real estate rental income in 27,438,520,000 of the instant building sales income in 2017, on the grounds that the said amount was generated in 2016, the immediately preceding taxable period, and reported and paid the comprehensive income tax calculated by applying the simple expense rate.

C. The director of the Busan Regional Tax Office conducted a comprehensive audit on the Silung Tax Office, and deemed that the Plaintiffs caused false real estate rental income to be subject to simple expense rate, and notified the Defendants of the rectification of global income tax by excluding the application of simple expense rate to the Plaintiffs. On May 1, 2019, the director of the Naman District Tax Office notified the Plaintiff B of the rectification of global income tax amount of KRW 964,965,980, global income tax amount of KRW 967,707,940, which belonged to the year 2017, and the director of the Silung Tax Office notified the Plaintiff A of the rectification and notification (hereinafter “each of the instant dispositions”).

The plaintiffs appealed and filed an appeal with the Tax Tribunal on July 16, 2019, but the Tax Tribunal dismissed the plaintiffs' appeal on October 22, 2019.

[Ground of recognition] Facts without dispute, Gap 1, 2, 10 evidence (including additional number; hereinafter the same shall apply), Eul 1, 2 evidence, Eul 4-3, 4-4 each entry, and the purport of the whole pleadings

2. Whether each of the dispositions of this case is legitimate

A. The Plaintiffs asserted that they commenced business in 2016.