1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance cited in this case is as stated in the reasoning of the judgment of the court of first instance, in addition to the parts to be filled or added below, and thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

At the second bottom of the judgment of the first instance, two types of “scambling” shall be applied to “scambling, which is based on the former Enforcement Rule of the Value-Added Tax Act, and thus contravenes the principle of no taxation without law.”

The following shall be added to 5 pages 5 of the judgment of the first instance and 4:

(1) The Plaintiff argues that the Plaintiff’s transfer of real estate to the Dong-gu Incheon Metropolitan City is not subject to value-added tax as it constitutes a comprehensive transfer or acquisition of the business, but in light of the Plaintiff’s real estate acquisition and transfer circumstances, it is reasonable to view that the above building is also subject to transaction while carrying on real estate sales business. Thus, the Plaintiff’s transfer of real estate to the Dong-gu Incheon Metropolitan City building is not subject to value-added tax. Thus, the Plaintiff’s transfer of real estate is subject to a disposition that violates the principle of no taxation without law because it is based on Article 1(1) of the former Enforcement Rule of the Value-Added Tax Act (including the case of newly constructing and selling real estate) (including the case of selling real estate at least once during one taxable period, and if real estate is acquired and sold more than twice during one taxable period for business purposes). However, the Plaintiff asserts that the disposition in this case is a disposition that is subject to no taxation without law, but the same shall apply to the former Value-Added Tax Act (amended by Act No. 6049, Dec. 28, 19

Article 1 (5) shall delegate necessary matters concerning the scope of goods and services under paragraph (1) subject to taxation to Presidential Decree. Accordingly, the proviso to Article 2 (1) 5 of the former Enforcement Decree of the Value-Added Tax Act shall apply.