1. Revocation of a judgment of the first instance;

2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

1. The reasoning for the court’s explanation concerning this case is as follows: (a) adding the following two judgments to the 10th judgment of the court of first instance, following the 10th judgment of the court of first instance; and (b) excluding the 12th judgment of the court of first instance as stated in the reasoning of the judgment of the court of first instance; and (c) citing this case in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act

2. Article 17-3(1)7 of the Enforcement Rule (amended by Ordinance of the Ministry of Strategy and Finance No. 223, Jul. 26, 201) provides that “Where the normal sales period in major types of business is less than three years” is unreasonable to assess the weighted average amount of net profit and loss for the last three years per week. Since the normal sales period of paid construction is less than three years, the Plaintiff asserts that the instant disposition which assessed the instant stocks based on this is unlawful, since it cannot calculate the net profit and loss value based on the net profit and loss value for the last three years of paid construction.

Article 56 (1) of the Enforcement Decree provides that where it is unreasonable for the relevant corporation to make the net profit or loss at a price based on the weighted average of the net profit in the last three years each week, such as an abnormal increase in the amount of net profit or loss for the last three years, the value under subparagraph 2, namely, the value under subparagraph 2, namely, the average value of the presumed profit per share calculated according to the standards set by Ordinance of the Ministry of Strategy and Finance by the credit appraisal institution, etc. specified by Ordinance of the Ministry of Strategy and Finance, and Article 17-3 (1) of the Enforcement Rule provides that "a case prescribed by Ordinance of the Ministry of Strategy and Finance" under Article 17-3 (1) 7 of the Enforcement Decree refers to a case where the normal sales period is less than three years in the main type of business (referring to the business which is the largest value of the tangible fixed asset directly used by the relevant corporation among