1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasoning for this part, such as the acceptance of the judgment of the court of first instance, is as follows: “Electronic” under the fourth below of the judgment of the court of first instance; “No one appears to have existed,” “Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act,” and “No one appears to have existed under the fifth below,” “No one appears to have divided the part designated as a planned road area after the urban planning decision and no one had engaged in development activities on the remaining land”; “The possibility of future alteration of use” under the seventh five parallel parallel shall be written as “the ground for acquisition, etc.”; and this part of the reasoning of the judgment of the court of first instance shall be cited in addition to the supplementary decision as to the Plaintiff’s repeated argument made by this court, as it is stated in the part of the reasoning of the judgment of first instance, in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Supplementary judgment

A. The Plaintiff’s assertion that the Plaintiff did not either construct a building on the instant land or endeavor to implement the authorization and permission procedure for changing the form and quality of the land is merely the Plaintiff’s subjective intent. Thus, Article 168-14(1)4 of the former Enforcement Decree of the Income Tax Act and Article 83-5(1)12 of the former Enforcement Rule of the Income Tax Act need to impose taxes on the landowner’s subjective intent

Since the land of this case is not defined as non-business land, it is against the principle of strict interpretation derived from the principle of no taxation without law to determine whether it constitutes non-business land.

B. As long as Article 168-14(1)4 of the former Enforcement Decree of the Income Tax Act provides that “land falling under any inevitable cause prescribed by Ordinance of the Ministry of Strategy and Finance, considering statutory restrictions due to other public interests, corporate restructuring or inevitable causes, the current status of land, grounds for acquiring or using land, etc.” as the criteria for determining land not deemed land for non-business use, Article 83-5(1) of the former Enforcement Rule of the Income Tax Act delegated