1. The part of the judgment of the court of first instance against the plaintiff shall be revoked.

2. On December 5, 2012, the Defendant reverted to the Plaintiff on December 5, 2011.

1. This part of the judgment of the court below is the same as the corresponding part of the court of first instance (the two pages 5 to 18). Thus, this part of the judgment is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Whether the instant disposition is lawful

A. This part of the Plaintiff’s assertion is identical to the corresponding part of the first instance trial (from March to 11). Therefore, this part of the judgment is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

B. In a case where the Plaintiff acquired real estate with the Defendant’s assertion and the Plaintiff did not know the initial acquisition value, which serves as the basis for calculating basic inventory assets, the amount converted into sales cannot be calculated, and in such a case, the amount of income cannot be calculated by the formula

In addition, if there is no basis to prove the value of real estate under the principle of the Income Tax Act, it is reasonable to calculate it as individual

Nevertheless, the Plaintiff calculated the principal expenses by applying the sales of the relevant year of the basic inventory as the sales conversion amount.

In the case of global income tax attributed to year 201, in order to apply the amended notice, major expenses included in the inventory assets as of the end of the taxable year should be separately calculated. However, there is no evidence to compute the Plaintiff’s inventory assets at the end of the taxable year. Therefore, it is not a matter that can calculate major expenses by applying the provisions of Article 4(3) of the amended notice.

C. This part of the judgment by relevant law is identical to the corresponding part of the first instance court (8 to 11 pages), except for the addition of the following matters, and thus, this part of the judgment is quoted in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the

The following shall be added to the four upper parts at the bottom of the nine pages:

"Other cases prescribed by Ordinance of the Ministry of Strategy and Finance" in Article 95-2 (Special Cases concerning Evidence of Expenses, etc.) of the former Enforcement Rule of the Income Tax Act (wholly amended by Ordinance of the Ministry of Strategy and Finance No. 265 on February 28, 2012) refers to "other cases prescribed by Ordinance of the Ministry of Strategy and Finance."