1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The Plaintiff, as a project implementer, was entrusted with a lot of land of 2056, Seo-gu, Seo-gu, Seo-gu, Seo-gu, Seo-gu, Seo-gu, 2056, the Plaintiff implemented a new construction project with 481 households and 14 households of neighborhood living facilities (hereinafter collectively referred to as the “instant apartment”). On October 10, 2014, the Plaintiff obtained approval for the use of the instant apartment on the ground.

B. The buyer of the instant apartment from October 2014 occupied and resided in the instant apartment from around October 2014.

C. On November 4, 2014, the Plaintiff calculated the acquisition price, which is the tax base, as KRW 84,279,906,903, based on the construction cost required to newly construct the instant apartment, financial expenses, etc., and paid the acquisition tax of the instant apartment as KRW 2,359,837,390, local education tax, KRW 134,847,850, and KRW 102,131,370.

On December 30, 2014, the Plaintiff reported and paid an additional amount of KRW 55,645,50,050, local education tax, and special rural development tax, and KRW 2,294,150,000, which are equivalent to KRW 1,83,57,489, for the increased construction cost of the instant apartment.

E. On December 11, 2015, the Minister of the Interior rendered authoritative interpretation that “The charges for school sites paid during the process of acquiring real estate constitutes acquisition price which serves as the tax base for acquisition tax provided under Article 18(1) of the Enforcement Decree of the Local Tax Act” (hereinafter “instant authoritative interpretation”).

F. On December 30, 2015, the Cheongnam-do governor conducted a tax investigation on the Plaintiff’s acquisition of the instant apartment, and notified the Plaintiff of the result of the tax investigation to collect the increased amount of KRW 25,447,69, local education tax, KRW 1,454,150, and KRW 1,101,350, by including KRW 908,846,469, paid by the Plaintiff as school site charges, in addition to the acquisition price of the instant apartment.

G. On January 12, 2016, the Defendant: (a) based on the results of the tax investigation conducted on the Plaintiff, KRW 25,447,690, the acquisition tax of the instant apartment.