1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning of the judgment of the court of first instance citing the instant case is as follows, except for the addition of the following Paragraph 2 to the judgment on the argument that the plaintiff emphasizes as the grounds for appeal or is going to emphasize as the grounds for appeal, and thus, the reasoning of the judgment of the court of first instance citing this case is as stated in Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

From the fifth bottom of the judgment of the court of first instance, the phrase " February 28, 2018" in the third part shall be deemed to read " February 26, 2018".

The 6th judgment of the first instance court " declared and paid" is as follows.

“A return, and on February 28, 2018, the tax amount paid, including additional taxes, was 229,282,910 won for acquisition tax, special rural development tax, 57,320,710 won for rural development tax, and 22,928,280 won for local education tax.

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2. Additional determination

A. The main point of the Plaintiff’s assertion is that there is an illegal defect that deviates from or abused discretionary power, and such defect is deemed to have succeeded to the instant disposition.

B. (1) In the event two or more administrative dispositions are continually conducted, if there is a defect in the preceding dispositions when the two or more preceding dispositions are combined with each other and the subsequent dispositions are completed, the defect is succeeded to the subsequent dispositions. Therefore, even if the preceding dispositions are not in dispute and their validity cannot be asserted, the validity of the subsequent dispositions can be asserted on the grounds of the defect in the preceding dispositions.

On the other hand, when the preceding and subsequent dispositions are aimed at separate legal effects independently, the validity of the preceding dispositions shall not be asserted on the grounds of defects of the preceding dispositions, except where the defects of the preceding dispositions are grave and obvious and it is impossible to dispute the validity thereof.

However, the purpose of the preceding and subsequent dispositions is to separate effects independently from each other.