1. The plaintiff's claim is dismissed.

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

Head of Gu Office A No. 1, and B.

1. Details of the disposition;

A. On January 15, 2009, the Plaintiff acquired each apartment house B in Gwangjin-gu, Seoul, 302.94 square meters, and on January 19, 201, 201, apartment house D, 267.84 square meters (hereinafter referred to as “old house”) on the same ground. On April 30, 2014, the Plaintiff registered the construction business (housing Construction and Sales Business) with its business place.

On February 10, 2015, the Plaintiff reported the amount of revenue at the time of report on current status of tax-free business operators for the year 2014.

B. On December 30, 2014, the Plaintiff removed previous housing units, and newly built 12 households of multi-household houses (a total floor area of 659.87 square meters, 5 stories, 1 storys, 200; hereinafter “instant housing”) on the same site by June 30, 2015 (hereinafter “instant housing”). Upon filing a comprehensive income tax return for the year 2015, the Plaintiff filed a return on KRW 425,506,500 of estimated income amount by applying the simplified expense rate of KRW 3,431,50,000.

C. After conducting a regular comprehensive audit against the director of the Incheon District Tax Office (hereinafter “the audit of this case”), the director of the Central District Tax Office instructed the Plaintiff to apply standard expense rate, which is not a simple expense rate, on the ground that the Plaintiff was a new business operator in 2015 who did not have any income in 2014. On October 10, 2017, the Defendant notified the Plaintiff of the taxation data from the director of the Incheon Tax Office, and notified the Plaintiff of the rectification and notification of the global income tax amounting to KRW 271,157,530 (hereinafter “instant disposition”).

On August 29, 2017, the Plaintiff filed a request for pre-assessment review on October 16, 2017, but was dismissed on June 12, 2018.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2, 4, Eul evidence 1 to 9, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. For the following reasons, the Plaintiff’s assertion constitutes a person subject to the application of simple expense rate under Article 143(4)2(b) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 26982, Feb. 17, 2016; hereinafter the same).

1 The plaintiff on December 2014.