1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. B, from July 16, 2002, operated an animal source with the trade name “D” in Goyang-gu, Seoyang-gu, Seoyang-gu, Seoul. On August 31, 2013, B entered into an investment-in-kind agreement with the Plaintiff, a company established during the establishment on August 31, 2013, to comprehensively contribute assets and liabilities, including 442,976 square meters of land E-si, in order to transfer the animal source and convert the corporation.

B. On November 4, 2013, B established the Plaintiff, and on December 31, 2013, B completed the registration of ownership transfer for the said E land according to the said investment in kind contract to the Plaintiff.

C. On January 2, 2014, the Plaintiff was exempted from acquisition tax, etc. pursuant to Article 44 of the former Restriction of Special Local Taxation Act (amended by Act No. 13637, Dec. 29, 2015; hereinafter the same) on the ground that the said E’s land constitutes real estate acquired by a person who is scheduled to be used as an animal source site (hereinafter “instant land”) to use for a lifelong educational establishment.

However, around November 2015, the Defendant: (a) indicated that the Plaintiff did not directly use the instant land for the above purpose without justifiable grounds; and (b) on April 11, 2016, the Defendant imposed acquisition tax of KRW 29,930,890, special rural development tax of KRW 1,274,230, and local education tax of KRW 2,548,48,480, respectively, on the Plaintiff (hereinafter “instant disposition”).

E. The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on June 14, 2016, but the Tax Tribunal dismissed the appeal on November 28, 2016.

【Ground of recognition】 The fact that there is no dispute, Gap's 1 through 4, 9, 12, 14 through 16, 52 through 54, Eul's 1 and 3, and the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion is subject to strategic environmental impact assessment consultation, reports on temporary use of the instant land, determination of an urban management plan, and announcement of topographic drawings to use the instant land directly for animal’s original purpose.