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 November 9, 201, the Plaintiff completed business registration (30% of the Plaintiff’s equity ratio) under the Housing Construction and Sales Business Act, and closed business on December 20, 2012.

B. On October 26, 2011, the Plaintiff and B obtained a building permit to newly construct 12 households of multi-household housing (hereinafter “instant housing”) on the ground of Guro-gu Seoul Metropolitan Government, Guro-gu, and sold the housing after obtaining approval for use on March 8, 2012.

C. When the Plaintiff filed a comprehensive income tax for the year 2012, the Plaintiff: (a) sold by-products of the former building in 2011, which was the taxable period immediately preceding the year 2012; and (b) returned 960,000 won below the amount prescribed in Article 143(4)2(b) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 24356, Feb. 15, 2013; hereinafter the same shall apply), the Plaintiff calculated estimated income by applying the simple expense rate under the above provision; (b) applied the special tax reduction and exemption for small and medium enterprises pursuant to Article 7(1) of the former Restriction of Special Taxation Act (amended by Act No. 12853, Dec. 23, 2014; hereinafter the same shall apply); and (c) reported and paid the comprehensive income tax accordingly.

As a result of the consolidated investigation of the Plaintiff, the director of the Seoul Regional Tax Office notified the Defendant of taxation data to the effect that: (a) the Plaintiff is a new business operator who commenced business in 2012 with the sales revenue of the instant house; (b) the amount of income exceeds the standard amount under Articles 143(4)1 and 208(5)2 of the former Enforcement Decree of the Income Tax Act; (c) the amount of income should be estimated by applying the standard expense rate rather than the simple expense rate; and (b) the Plaintiff did not engage in construction business; and (c) the Plaintiff notified the Defendant of taxation data to the effect that the special tax reduction

E. Accordingly, the Defendant, on August 1, 2017, imposed global income tax of KRW 52,076,590 (including additional tax) on the Plaintiff for the year 2012.