1. All of the plaintiff's claims are dismissed.

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

Details of the disposition

As shown in attached Table 1, the Plaintiff acquired an unsold apartment unit in Daegu-gu B apartment on September 24, 201, and the household on January 28, 201 (hereinafter “instant apartment”) on September 20, 201, and filed a report on capital gains tax reduction by 100% pursuant to Article 98-5 of the Restriction of Special Taxation Act while transferring each of the two households in 2011, 201, 12 households in 2012, and 8 households in 2013.

From December 8, 2016 to February 13, 2017, the head of Busan Regional Tax Office conducted an individual consolidated investigation on the Plaintiff (Suspension from December 14, 2016 to January 2, 2017) and notified the Defendant of the result that the Plaintiff had continued to engage in real estate trading, including continuous acquisition and transfer of a large number of real estate between 2010 and 2013.

Accordingly, the Defendant imposed the value-added tax on January 11, 201 and the global income tax on March 16, 2017, respectively, on the following grounds that the Plaintiff engaged in real estate sales for profit, and transferred 22 households’ apartment houses between 2011 and 2013.

(2) The Plaintiff’s disposition of imposition of value-added tax and global income tax on the Plaintiff (hereinafter “instant disposition”). The Plaintiff’s disposition of imposition of value-added tax on the second term portion in 2011 and the second term portion in 2012,041,630 won in total in 22,041,630 won in 24,96,950 won in 95,901,170 won in 22,778,110 won in 165,687,860 won in global income tax for the year 2013 and 33,828,320 won in total in 472,598,860 won in 298,32,190 won in 80,759,370 won in total in 2013 was dismissed by the Tax Tribunal, and the Plaintiff’s remaining disposition of imposition of penalty tax on the 1917.18.

The defendant revoked the penalty tax according to the decision of tax appeal and made a decision of reduction of penalty amount as follows:

Value-added tax for the second period of February 201, 201 and for the second period of February 2012, 2013, KRW 14,771,790 in total, KRW 15,17,740 in total, KRW 60,043, KRW 310 in total, KRW 14,771, KRW 790 in total, KRW 104,704,630 in total.