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 first instance is as follows, except for the following additional determination as to the Plaintiff’s assertion that is emphasized by this court, the reasoning of the judgment of the first instance is the same as that of the judgment of the first instance.

2. Additional determination

A. The decision of the ruling authority is final interpretation of the requirements for the disposition of additional collection because the tax authority cannot object to the decision of the ruling authority. In the case of merger and division, the decision of the ruling authority is no longer likely to dispute since the decision under the legal principles that cannot be seen as sale or donation under Article 78(5)2 of the former Restriction of Special Local Taxation Act was made by the ruling authority. ② The purpose, meaning, function, etc. of Article 78(4) and (5) of the former Restriction of Special Local Taxation Act, which serves as the basis for the disposition of additional collection, should be considered as a purposeological and reasonable consideration of the specific characteristics of the case at the same time, and even if the plaintiff newly constructed the building and used it as an industrial building and still used as an industrial building even after the general succession, the disposition of this case was conducted even after the general succession, and thus the disposition of this case was null and void, and thus the plaintiff should return the tax amount paid by the plaintiff as unjust enrichment.

B. Even if the tax authority is unable to object to the decision of the ruling authority through administrative litigation, the decision of the ruling authority can also be revoked by judicial judgment, so the decision of the ruling authority cannot be deemed final legal interpretation. Article 78(5) of the Restriction of Special Local Taxation Act does not state justifiable grounds, and Article 78 of the Restriction of Special Local Taxation Act is related to Article 78 of the Restriction of Special Local Taxation