1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. On October 19, 201, the Plaintiff established a legal entity as civil engineering works, milk-using machinery and equipment manufacturing business, and construction machinery parts manufacturing business. On November 9, 2011, the Plaintiff added automobile parts manufacturing and maintenance business to the intended business.

B. On February 15, 2012, the Plaintiff acquired the B building 1,732.95 square meters in Gwangju-do, Jeonyang-do, and on February 14, 2013, the said lot number of land 3,966.9 square meters in combination with the said building and land (hereinafter “instant real estate”).

C. On February 22, 2012, the Plaintiff registered a factory as “a business of manufacturing civil engineering works and gene-use machinery and equipment (29241),” and on February 27, 2012, registered construction machinery maintenance business by applying the type of registration as “part-of-construction machinery maintenance business (total type)” as “part-of-construction machinery maintenance business.”

After that, the Plaintiff filed an application for reduction or exemption of acquisition tax, etc. on the ground that the instant real estate constitutes “business property acquired by a small or medium start-up enterprise within four years from the date of establishment” under Article 120 of the former Act on Special Cases concerning the Restriction of Taxes (Act No. 11486, Oct. 2, 2012; hereinafter “Special Cases concerning the Restriction of Taxes”). Accordingly, the Defendant reduced or exempted totaling KRW 86,157,960, including acquisition tax, KRW 75,624,340, special rural development tax, KRW 4,591,220, local education tax, and KRW 5,942

E. However, as a result of the tax investigation conducted from July 17, 2017 to July 28, 2017, the Defendant determined that the Plaintiff did not directly use the instant real estate for the pertinent business within two years from the date of acquisition without justifiable grounds, and rendered a disposition to impose acquisition tax of KRW 43,215,860, local education tax of KRW 2,314,840, and special rural development tax of KRW 2,700,310, ② Disposition to impose acquisition tax of KRW 54,863,310, local education tax of KRW 4,748,920, and imposition of KRW 2,374,450, ③ Acquisition tax of KRW 17,158,820, Local education tax of KRW 919,090, special rural development tax of KRW 1,072,150 (each of the above dispositions is collectively referred to as “disposition disposition”).

F. On August 29, 2017, before the instant disposition, the Plaintiff filed a request for pre-assessment review of local taxes with the former Do governor.