1. The Defendant’s comprehensive real estate holding tax for the year 2010 (including additional tax) against the Plaintiff on July 1, 2014.

1. Details of the disposition;

A. On July 25, 2007, the Plaintiff, a company running a housing construction business, entered into a contract to purchase a total of 38,256 square meters of land A and 13,000 square meters (a total of 38,256 square meters (hereinafter “instant land”). On March 31, 2008, the Plaintiff completed the registration of ownership transfer on the instant land due to the said sale.

B. On December 9, 2009, the Plaintiff filed an application for exclusion of aggregate comprehensive real estate holding tax on the ground that the instant land was acquired by a housing construction business operator under Article 104-19(1) of the Restriction of Special Taxation Act to construct housing and constitutes land subject to approval of a business plan under the Housing Act within five years from the date of acquisition. Accordingly, the instant land was excluded from the subject of comprehensive real estate holding tax for the year from 2010 to 2012.

C. On March 31, 2008, the Defendant: (a) deemed that the Plaintiff, a housing construction business entity, obtained the instant land on March 31, 2008, but did not obtain approval of a business plan for housing construction under the Housing Act within five years thereafter; and (b) determined and notified the Plaintiff of comprehensive real estate tax and special rural development tax for the period from 2010 to 2012, as shown in attached Table 1, respectively.

(hereinafter collectively referred to as “instant disposition”)

D. The Plaintiff appealed and filed an appeal with the Tax Tribunal on March 23, 2015, but the Tax Tribunal dismissed the Plaintiff’s appeal on June 12, 2015.

[Ground of recognition] Facts without dispute, Gap evidence 1, 4, Eul evidence 1 and 3 (including each number in the case of additional evidence), the purport of the whole pleadings

2. The Plaintiff’s assertion is null and void of the transfer of ownership on March 31, 2008, since the Plaintiff completed the registration of ownership transfer on the instant land without obtaining approval of the competent authority’s amendment to the articles of incorporation necessary to dispose of the instant land, which is the basic property of the Shin Young-gun, a foundation.

After December 1, 2012, Suduk-gu.