1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The Plaintiff (former: B) is an individual entrepreneur who runs real estate sales business, etc. in the trade name of “C” from October 12, 2003 to “C”.

B. On October 20, 2003, the Plaintiff acquired KRW 3,430,00,000 of land for D miscellaneous land in Gyeonggi-gu, Gyeonggi-do (hereinafter “Before division”), and completed the registration of ownership transfer for shares of KRW 330/20,02 of land before division to E on August 17, 2004.

On December 1, 2004, the Plaintiff obtained authorization of an implementation plan for the creation of housing sites for land, etc. before subdivision from the head of Eunpyeong-gu and had F perform the said project.

C. On August 1, 2011, the Plaintiff sold each of the Plaintiff’s shares (i.e., KRW 19,692/20,022; hereinafter “instant shares”) out of the J-JT land divided from the land before subdivision to G, H, and I and completed the registration of ownership transfer in the name of the Plaintiff.

However, even at the time of the final return of global income tax accrued in 2011, the Plaintiff did not pay the tax base and tax amount of the business income related to real estate sales, including the income accruing from the transfer of the instant shares.

On March 23, 2017, the Defendant: (a) considered the Plaintiff to have earned business income from the transfer of shares in this case; (b) deducted the purchase cost from KRW 2 billion to major expenses; and (c) calculated the real estate sales business income by estimation by applying the standard expense rate of 8.3% (less than five years in land holding period); and (d) imposed global income tax of KRW 664,196,950 (including additional tax) on the Plaintiff for the year 2011.

E. On April 11, 2017, the Plaintiff filed an objection against the said disposition.

On May 26, 2017, the Defendant decided to revise the tax base and tax amount by applying the standard expense rate of 21% to the standard expense rate, and calculated the income amount for real estate sales business as listed below by applying 21% to the standard expense rate of 21%, and then the said amount of tax imposed on the real estate sales business income of KRW 976,473,154 shall be KRW 587,450,176.