1. Revocation of the first instance judgment.

2. On January 31, 2017, the Defendant filed a request for rectification of global income tax for the period of 2013, which belonged to the Plaintiff.

1. As to the details of the disposition, the part of the judgment of the court of first instance regarding “new construction and sale business” in 2-2, 18-2, 3-3, 11-2, and 20-20, 3-2, “the day of full payment” as “the day of full payment,” and the corresponding part of the reasoning of the judgment of the court of first instance, except where the “request for correction” is deemed as “request for correction.” Thus, the corresponding part of the reasoning of the judgment of the court of first instance shall be cited pursuant to Article 8(2) of the Administrative Litigation Act and Article 420 of the

2. To enter the details of the relevant statutes attached thereto;

3. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) The instant income amount is the former Income Tax Act (amended by Act No. 15225, Dec. 19, 2017; hereinafter the same applies).

(2) Article 17(1)8 of the Enforcement Decree of the Income Tax Act, regardless of whether to pay dividends, is the income accrued to the year 2008, which is the end of the taxable period pursuant to Article 46(3)-2 of the Enforcement Decree of the Income Tax Act regardless of whether to pay dividends. (2) Even if the instant income does not amount to the amount according to the ratio of distribution of profits and losses of joint investment businessmen, the instant income amount is agreed to dispose of the instant real estate by joint investment businessmen comprised of the Plaintiff, Taecheon Construction, Taecheon Construction, C, D, E, F (hereinafter “Plaintiff et al.”), and the disposal of the instant real estate by the joint investment businessmen constituted the “income accrued from the real estate business” under Article 19(1)12 of the former Income Tax Act. Since the instant income amount was derived from the disposal of the instant real estate to Taecheoncheon Comprehensive Construction, it should be deemed that the instant comprehensive construction constitutes the “income accrued from the real estate business” under Article 19(1)12 of the former Income Tax Act, and thus, it should be deemed unlawful from June 1, 2008 to 4.

3. The income amount in this case shall be the business income amount.