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 December 1, 2009, the Plaintiff newly constructed a factory building 6,220.1 square meters on August 23, 2013 on a leased land from the Korea Land and Housing Corporation and engaged in metal parts manufacturing business, etc., by establishing a personal business entity called “B”, which was located in the name of “B.”

(A) Article 78(4)1(a) and 2(a) of the former Restriction of Special Local Taxation Act (amended by Act No. 12175, Jan. 1, 2014; hereinafter the same shall apply) that grants exemption from acquisition tax on real estate acquired by a person who intends to construct an industrial building within an industrial complex (hereinafter “instant building”). The Plaintiff was exempted from acquisition tax pursuant to Article 78(4)1(a) and 2(a) of the Restriction of Special Local Taxation Act.

B. The Plaintiff decided to convert B into a corporation, and concluded an investment in kind contract with D, a company under incorporation, on October 2, 2013, and decided to contribute the instant building in kind.

D Co., Ltd. was established on October 22, 2013, and on November 4, 2013, the building of this case was registered to D on the ground of the said investment in kind.

[2] The Plaintiff owned 10% of the shares as representative director at the time of the establishment of the Plaintiff, and operates the Dispute Resolution Co., Ltd.

C. On January 17, 2018, the Defendant notified the Plaintiff of KRW 139,931,270 (including additional tax 16,912,160, and additional tax 38,458,270), local education tax, KRW 7,029,650 (including additional tax 2,197,610), special rural development tax, KRW 8,787,070 (including additional tax 2,747,010), total of KRW 15,747,090 (including additional tax 2,747,010) for rural development tax, and KRW 15,747,90.

The plaintiff is dissatisfied with the above disposition and filed a tax appeal.