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 entered into a contract to contract construction cost of KRW 27.1 billion for a construction project between a general construction project and a housing construction project (hereinafter “construction”) and a construction project company in 2003. The Plaintiff entered into a contract for construction of a major complex building (hereinafter “instant building”) with a 99-5 underground floor and 20th floor above the ground (299 households, commercial buildings, 14 households in Busan) in the construction.

(hereinafter “instant contract”). (b)

The construction of the instant building was completed in around 2006, and 14.85 billion won was not settled among the construction cost under the instant contract.

On July 27, 2006, the Plaintiff is a real estate unsold in lots with 305 households in the instant building [the housing 291 households and 14 households in lots (the housing unsold in lots; hereinafter referred to as “instant commercial building”)] among the instant buildings.

) The real estate disposal trust agreement (hereinafter “instant trust agreement”) was concluded with respect to the instant trust agreement, and the relevant trust agreement was designated as the preferred beneficiary, but no tax invoice was issued.

C. Accordingly, on January 9, 2012, the Defendant determined that the Plaintiff entered into the instant trust contract by designating the instant commercial building as a priority beneficiary, as the “supply of goods” under Article 1(1) of the Value-Added Tax Act, and issued a notice of correction and notification of KRW 4 billion, which is the expected sale price of the instant commercial building, as the market price of the instant commercial building, and KRW 2.66 million, which is the expected sale price of the relevant commercial building, as the tax base, KRW 2.45 million, which is the building price, as the second value-added tax of KRW 463,427,640, which is the building price.

(hereinafter “instant disposition”)

D. The Plaintiff filed an appeal on May 10, 2012, but was dismissed on October 31, 2012.

[Reasons for Recognition] Class A, Nos. 1, 3, 5, and No. 1, and the purport of the whole pleading

2. Whether the instant disposition is lawful

A. The Plaintiff’s expected sale price of the instant commercial building as alleged by the Plaintiff is prepared inside the lot construction.