1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. The reasons why this court should explain are the following.

2. In addition to the addition of the judgment on the Plaintiff’s assertion, the grounds for the judgment of the first instance court are the same, and thus, the same shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 4

2. Judgment on the plaintiff's assertion

A. The Plaintiff’s assertion (i) although the instant land should have been naturally included in the “D” urban development project zone, the Plaintiff was actually using the instant land in the “D” project zone because SH Corporation, which is the project implementer, did not include the instant land in the project zone, faced with the “D” project zone and the land boundary, and SH Corporation, etc. knew that the instant land is included in D’s project zone, thereby impairing the legal surface and conducting landscaping.

As such, it is difficult to restore the land to the original state due to such a circumstance, the request for purchase under Article 47 of the former National Land Planning and Utilization Act has been made through consultation with Seoul Special Metropolitan City

Therefore, there is no reason to view the instant land as different from the other land included in the D business zone, and thus, regarding the transfer of the instant land, it should be deemed as the date of the public announcement of the project approval or as the date of the request for purchase.

Article 104-3 (1) 4 of the former Income Tax Act.

According to the item, the land, the land category of which is a site is exempt from property tax under the "Local Tax Act" or related Acts and subordinate statutes, and the head of Eunpyeong-gu Seoul Metropolitan Government is confirmed to have disposed of non-taxation of 1/2,104.30 square meters among the land in this case, so the land in this case shall be excluded from the non-business land and shall be subject to special long-term holding deduction for such transfer income.

B. (i) As to the Plaintiff’s first argument, the Plaintiff’s statement Nos. 2 and 17 (including each number), and the purport of the entire pleadings.