1. On December 5, 2012, the Defendant imposed imposition of global income tax of KRW 191,198,340 on the Plaintiff for the year 2008.

1. Details of the disposition;

A. The Plaintiff, a person conducting real estate sales business with the trade name of “B,” calculated the “major expenses included in the basic inventory assets” among the main expenses under the notice given by the National Tax Service, included them in the necessary expenses, and reported and paid the global income tax as estimated income by standard expense rate.

B. On December 5, 2012, the Defendant re-calculated the estimated income amount on the ground that the evidence of disbursement for the principal expenses included in the basic inventory and for the principal expenses incurred during the current period was not verified, and notified the Plaintiff of the global income tax of KRW 191,198,340, the global income tax of KRW 171,370,120 for the year 2008 and the global income tax of KRW 171,370 for the year 201.

On the ground that the plaintiff raised an objection, the defendant re-revisiond and notified the plaintiff of the comprehensive income tax belonging to year 201 as KRW 155,149,912 on the ground that the purchase cost of real estate was additionally confirmed.

(hereinafter above, imposition of global income tax and global income tax in 2008 on global income tax in 201 (hereinafter “instant disposition”). C.

The Plaintiff appealed and filed an appeal with the Tax Tribunal on June 5, 2013, but the Tax Tribunal dismissed the appeal on April 21, 2015.

[Ground of recognition] Unsatisfy, Gap evidence 1, 2, 10, Eul evidence 1 to 3, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. In calculating the estimated income amount based on standard expense rate of the Plaintiff’s business income claimed by the Plaintiff, in the case of global income tax accrued in 2008, Article 2009-11 of the National Tax Service Notice (hereinafter “former Notice”) applies to the global income tax that reverts in 2008. Since there is no premise provision that “the principal expenses included in the final notice can be separately calculated” in the revised Notice, it is necessary to calculate the principal expenses in accordance with the conversion provision of “the principal expenses included in the base inventory as of the beginning date of the pertinent taxable year” under subparagraph 3(b) of the [Attachment Table 1] of the former Notice prior to the amendment, and in the case of global income tax