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 is an organization established for the purpose of carrying out apartment development projects (hereinafter “instant projects”) with the content of constructing 24 square and 34 square and 512 units of apartment units from the land B in Yeongdeungpo-gu Seoul Metropolitan Government (hereinafter “instant project site”), or there is no lack of authorization for the establishment of a regional housing association under the Housing Act.

B. On August 28, 2012, the Plaintiff reported and paid acquisition tax on 49 parcels of land, including land B and 33 parcels of land outside Yeongdeungpo-gu Seoul, Yeongdeungpo-gu. On September 24, 2013, the head of Yeongdeungpo-gu Seoul Metropolitan Government imposed property tax, etc. on the Plaintiff on the land of 58 parcels of land, including the said 49 parcels of land (hereinafter “each parcel of land”).

C. On November 16, 2013, the Defendant imposed a comprehensive real estate holding tax amounting to KRW 138,850,060 on the Plaintiff on November 16, 2013 (the amount was reduced to KRW 69,425,040 as a result of subsequent installment) and the comprehensive real estate holding tax amounting to KRW 47,636,070 on February 5, 2014.

(hereinafter collectively referred to as “instant disposition”). D.

On September 25, 2014, the Plaintiff filed an appeal with the Director of the Tax Tribunal for adjudication on September 25, 2014, but the appeal was dismissed on December 16, 2014.

[Reasons for Recognition] Facts without dispute, entry in Eul evidence Nos. 1 through 5 (including each number in the case of additional number) and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The person liable to pay comprehensive real estate holding tax is the person liable to pay property tax and the person liable to pay property tax on trust property. Each of the instant land is a trust property registered under the name of C (the former trade name: D.; hereinafter “C”) a trustee pursuant to the Trust Act, and is a trust relationship between the Plaintiff and the Plaintiff’s members with respect to each of the instant land. Accordingly, the Plaintiff’s members are the actual truster.