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The appeal is dismissed.
The costs of appeal are assessed against the Plaintiff.
Reasons
The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).
1. On the ground of appeal No. 1, the court below acknowledged facts as indicated in its reasoning based on its adopted evidence, and rejected the Plaintiff’s assertion that the Plaintiff acquired the instant land by acquiring the investor’s status as an investor in relation to the increased capital due to the investment in kind around May 16, 201, on the ground that the investment in kind constitutes acquisition by onerous succession by paying the shareholder’s rights and obligations as compensation for the acquisition of the goods by paying the price to the investor, or by registering the ownership transfer of the goods in kind, etc., should be considered to be the time of acquisition. In so doing, the court below rejected the Plaintiff’s assertion that the High Transfer Corporation, a corporation prior to the merger of the Plaintiff, received the instant land from the Goyang-si around May 2010 after the merger of the Plaintiff, which was a corporation prior to the merger, should be deemed to have been acquired by the merger
In light of relevant provisions, legal principles, and records, such determination by the court below is just, and contrary to the allegations in the grounds of appeal, there is no error of law by misapprehending the legal principles on the time of acquisition
2. As to the grounds of appeal Nos. 2 and 3, Article 13 of the former Ordinance on the Reduction and Exemption of Do Taxes (wholly amended by Ordinance No. 4295, Dec. 26, 2011; hereinafter “instant Ordinance on the Reduction and Exemption”), which provides for the reduction and exemption of local taxes pursuant to delegation under Article 4(1) of the former Restriction of Special Local Taxation Act (amended by Act No. 12175, Jan. 1, 201); and Article 13(1) of the former Ordinance on the Reduction and Exemption of Do Taxes (wholly amended by Ordinance No. 4295, Dec. 26, 201; hereinafter “instant Ordinance on the Reduction and Exemption of Do Taxes”) provides that “acquisition