1. All of the plaintiff's claims are dismissed.

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

The circumstances of the instant disposition B Co., Ltd. (hereinafter “B”) was established on January 6, 1966 for the purpose of engaging in the manufacture and sale of bottles, the printing and removal of metals, etc., and established C Co., Ltd. (hereinafter “C”) on August 20, 2009 by dividing the investment and rental business sector into human resources.

(hereinafter “instant division”). On September 4, 2009, C acquired ownership of 10 buildings and land (hereinafter collectively referred to as “instant real estate”) out of 8/1,000 square meters out of 3,757 square meters in Gangnam-gu Seoul Metropolitan Government, Seoul, and 2,772 square meters in total, 8,772 square meters in E-building on the ground of the instant division, and of 10 square meters in Gangdong-gu Seoul Metropolitan Government F parking lot 1,354 square meters in total.

C was exempted from acquisition tax and registration tax on the instant real estate pursuant to Articles 119(1)10 and 120(1)9 of the former Restriction of Special Taxation Act (amended by Act No. 9924, Jan. 1, 2010; hereinafter the same) on the ground that the instant division constitutes qualified division satisfying the requirements of each subparagraph of Article 46(1) of the former Corporate Tax Act (amended by Act No. 9898, Dec. 31, 2009; hereinafter the same).

On December 4, 2009, the Plaintiff merged C with each other (hereinafter “instant merger”) was dissolved on the same day.

On December 21, 2009, the Plaintiff acquired the ownership of the instant real estate by reason of the instant merger.

Around April 2014, the Seoul Special Metropolitan City Mayor conducted a tax investigation on the Plaintiff, and determined that C does not constitute the subject of exemption from acquisition tax and registration tax on the instant real estate because it did not meet the requirement of “a corporation established by division, etc., shall continue to engage in the business succeeded from a divided corporation until the end of the business year in which the registration date of the division falls,” under Article 46(1)3 of the former Corporate Tax Act, since C was newly established on August 20, 2009 and merged in the instant case on December 4, 2009.

Accordingly, the head of Gangnam-gu Seoul Metropolitan Government pre-announcement of taxation on September 11, 2014.