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.

The reasoning of the judgment of the court of first instance cited by the court of first instance is as stated in the reasoning of the judgment of the court of first instance, except for the dismissal of the part on 5 to 6 pages of the judgment of the court of first instance as follows. Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 4

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C. Article 55-2(1)3 of the Corporate Tax Act provides that where a corporation transfers non-business land, the amount of tax calculated by multiplying the transfer income of the land by 10/100 shall be paid in addition to the amount of corporate tax. Article 55-2(3) of the Corporate Tax Act provides that where the use of the land is prohibited pursuant to a statute after the acquisition of the land, or where the land falls under non-business land due to an unavoidable reason prescribed by

Examining the provisions of Article 92-11 (1) 3 of the Enforcement Decree of the Corporate Tax Act and Article 46-2 (1) 6 of the Enforcement Rule of the Corporate Tax Act following delegation, the Enforcement Decree stipulates that “the land falling under inevitable causes prescribed by Ordinance of the Ministry of Strategy and Finance, considering the statutory restrictions due to the unavoidable causes, such as corporate restructuring or other inevitable causes, the current status of the land, the reason for its acquisition, or the current status of the use, etc.” shall be listed as “land acquired to exercise mortgage and other claims,” and the Enforcement Rule lists “land acquired to obtain mortgage and other claims,” which does not fall under any subparagraph of Article 5-2 (2) of the Corporate Tax Act for two years from the date of its acquisition, to determine whether it falls under the land

In full view of the structure, language, and legislative intent of the above corporate tax-related Acts and subordinate statutes, it is reasonable to deem that the land acquired “to receive a bond” refers to the land acquired with the main purpose of the repayment of the bond.

In other words, the time of acquisition.