1. All of the plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

1. Details of the disposition;

A. Plaintiff A constructed 16 households of apartment housing in Songpa-gu Seoul Metropolitan Government (16 households of total floor area of 990.37 square meters; hereinafter “the instant one house”) and sold it in around 2016. Plaintiff B constructed 16 households of apartment housing located in Dongjak-gu Seoul Metropolitan Government D and one parcel (1,070.93 square meters of total floor area; hereinafter “instant two houses”); and sold each of the instant houses, including the instant one, around 2014.

B. In relation to each of the instant houses, the Plaintiffs registered their business as indicated in the following table, and reported and paid comprehensive income tax by applying the provisions on special tax reduction and exemption to small and medium enterprises pursuant to Article 7(1) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 28637, Feb. 13, 2018; hereinafter the same shall apply) in the taxable period immediately preceding the pertinent year, if the amount of income falls short of the amount prescribed in Article 143(4)2(b) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 28637, Feb. 13, 2018; hereinafter the same shall apply).

- Plaintiff A 100% Seoul Songpa-gu C Construction/Housing New Construction and Sale on August 17, 2015, Plaintiff B 100% of the E Housing Construction/Housing Construction and Sale on August 7, 2015, Dongjak-gu Seoul, and 1 parcel construction/Housing Construction and Sale on August 7, 2013 (the date of business closure)

C. From January 18, 2018 to February 14, 2018, the Seoul Regional Tax Office: (a) conducted a personal integration survey with respect to the Plaintiffs during the period from January 18, 2018 to February 14, 2018, deemed that the Plaintiffs are not subject to the simplified expense rate; (b) notified the Defendant of the amount of income calculated by estimation based on standard expense rate; and (c) excluding special tax reduction and exemption for small and medium enterprises;