The plaintiff's appeal is dismissed.

Expenses for appeal shall be borne by the plaintiff.

Purport of claim and appeal

The judgment of the first instance.

1. The reasoning of the court’s explanation as to this case is as follows, except for the modification of Articles 8(2) and 4(8) through 14 of the judgment of the court of first instance as to this case, and therefore, it is identical to the ground of the judgment of the court of first instance. Thus, it is acceptable in accordance with Article 8(2) of the Administrative Litigation Act and the text

2. The revised portion of taxation is not subject to the principle of no taxation without law.

Dried or Non-Taxation

Summary of Tax Reduction and Exemption

The interpretation of tax laws and regulations shall not be interpreted in accordance with the text of the law, unless there are special circumstances, and it shall not be permitted to expand or analogically interpret without reasonable grounds, in particular, the need for reduction and exemption.

It is also consistent with the principle of equity in taxation to strictly interpret that it is a clear preferential provision among the provisions that can be seen as a clear preferential provision.

(See Supreme Court Decision 2008Du11372 Decided August 20, 209). The decision is based on the above legal principles, and the land of this case was transferred on March 6, 2009 after being incorporated into a residential area on June 27, 2005, which was before the execution of the development project, and the land was not incorporated into a residential area due to the implementation of the development project. Thus, it is not a land incorporated into a residential area, so the need for reduction or exemption as prescribed by Article 69 (1) of the Restriction of Special Taxation Act and Article 66 (4) 1 of the Enforcement Decree of the same

shall not have any case.

Therefore, the plaintiff's above assertion is without merit.

3. Thus, the plaintiff's claim is dismissed as it is without merit, and the judgment of the court of first instance is just, and the plaintiff's appeal is dismissed. It is so decided as per Disposition.