1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The Plaintiff registered as a real estate sales businessman on February 1, 2013.

The Plaintiff newly built a commercial building on the land Kimpo-si B, and sold 54 stores from February 2014 to November 2014.

B. A real estate sales businessman shall file a preliminary return with the head of the competent tax office by the date two months elapse from the end of the month in which the sales date belongs and pay the tax amount [Article 69(1), (3), and (4) of the former Income Tax Act (amended by Act No. 15225, Dec. 19, 2017)]; the Plaintiff did not pay the preliminary return and its subsequent return by the date two months elapse from the end of the month in which the sales date of the store belongs.

C. On June 30, 2015, the Plaintiff within the final return period of global income tax base, the Plaintiff is a business operator subject to verification of bona fide return. As such, the final return period is by June 30.

The final tax base return for global income for 2014 including income from the sales of stores was filed, and the comprehensive income tax was paid on June 30, 2015 and August 24, 2015.

The defendant filed a final return of global income tax base, including income from the sales of a store in lots, and paid taxes, but the above B.

On June 9, 2017, on the ground that preliminary return and its payment were not made, the Plaintiff imposed KRW 224,769,510 on the Plaintiff, and KRW 109,341,79,790 on the additional tax for unfaithful payment.

(hereinafter “Disposition in this case”). 【No dispute exists, Gap’s evidence 1, 3, Eul’s evidence 1, and the purport of the entire pleadings

2. The attachment to the relevant Acts and subordinate statutes shall be as follows;

3. Whether the instant disposition is lawful

A. Article 129(3) of the Enforcement Decree of the Income Tax Act provides that “The head of the competent tax office shall determine the profit margin and tax amount for a person who has filed a provisional return resulting from the provisional return, within one month from the date of filing the return and payment, and for a person who has failed to file a provisional return resulting from the provisional return,