The judgment below is reversed and the case is remanded to Seoul High Court.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1.(a)

Articles 9(3), 14(3), and 14(6) of the former Gross Real Estate Tax Act (amended by Act No. 10221, Mar. 31, 2010; hereinafter the same) provide that the amount of property tax imposed on the relevant taxable housing, etc. shall be deducted from the amount of comprehensive real estate holding tax on housing, the amount of comprehensive real estate holding tax on land, and the amount of comprehensive real estate holding tax on land, etc. (hereinafter referred to as “house, etc.”) separately aggregate tax on land, etc.

B. First, the lower court acknowledged the following facts: (a) on each disposition date listed in the [Attachment 1] No. 1 to 26 of the [Attachment 2] Disposition List, the Defendants imposed comprehensive real estate tax and special agricultural and fishing villages tax on the relevant Plaintiffs, including housing in 2009; and (b) on February 23, 2010, the head of the secondary tax office having jurisdiction over the Defendants issued a disposition rejecting a request for correction of comprehensive real estate tax and special agricultural and fishing villages tax (hereinafter “each disposition of this case”), and (c) each amount of property tax to be deducted from the amount of comprehensive real estate tax, such as housing, etc. (amended by Ordinance of the Ministry of Strategy and Finance No. 102 of September 23, 2009) prescribed in Article 5(2) [Attachment 3] of the former Enforcement Rule of the Comprehensive Real Estate Tax Act (amended by Ordinance of the Ministry of Strategy and Finance No. 102] 】 Fair market price ratio of comprehensive real estate holding tax 】 property tax rate (hereinafter “the instant formula”).

Furthermore, the lower court (A) Article 4-2 and Article 5-3(1) and (2) of the former Enforcement Decree of the Gross Real Estate Tax Act (amended by Presidential Decree No. 22813, Mar. 31, 201; hereinafter the same) are deducted from the amount of comprehensive real estate holding tax, such as a house.