1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. On May 10, 2012, the Plaintiff completed the registration of a housing construction and sales business jointly with B and C.

B. On May 1, 2012, the Plaintiff obtained a construction permit to newly build a multi-household house with a total floor area of 847.24 square meters and 13 households in Guro-gu Seoul Metropolitan Government (hereinafter “instant housing”) on the land, and obtained approval for use on October 9, 2012 after commencing the construction on May 6, 2012.

C. When the Plaintiff filed a comprehensive income tax for the year 2013, the Plaintiff calculated estimated income by applying the simple expense rate pursuant to Article 143(4)2(b) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 25193, Feb. 21, 2014; hereinafter the same) and applied the special tax reduction and exemption for small and medium enterprises pursuant to Article 7(1) of the former Restriction of Special Taxation Act (amended by Act No. 12173, Jan. 1, 2014; hereinafter the same).

As a result of the consolidated investigation of the Plaintiff, the head of the Seoul Regional Tax Office notified the Defendant of the taxation data to the effect that: (a) the Plaintiff is a new entrepreneur who commenced business in the year 2013 in which the sales revenue amount of the instant house occurred; (b) the amount of income exceeds the standard amount under Articles 143(4)1 and 208(5)2 of the former Enforcement Decree of the Income Tax Act; (c) the amount of income should be estimated by applying the “standard expense rate” instead of the “simplified expense rate”; and (b) the Plaintiff did not engage in construction business; and (c) the tax data to the effect that

E. On August 1, 2017, the Defendant issued a revised notice of global income tax of KRW 250,185,550 (including additional tax) for the Plaintiff for the year 2013.

(f) The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on April 6, 2018, but was dismissed on June 29, 2018.