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 June 27, 2011, the Plaintiff entered into a contract on the sale of state forest products (hereinafter “instant contract”) with the Republic of Korea (Yancheon-gun Office of National Forest Administration) to purchase active leaves, which are state-owned forest products, from Class 1, 2014.33 cubic meters (15,011; hereinafter “instant standing timber”) on the ground that it is state-owned forest products on the ground B, YY-gun, YY-gun, YY-gun, YY-gun, and paid the remainder on July 6, 201.

B. On August 12, 2015, the Defendant issued each imposition of acquisition tax of KRW 1,685,930 (including additional taxes) and KRW 168,590 (including additional taxes) on the ground that the Plaintiff did not file a return on and pay acquisition tax on the said standing timber, and the Defendant did not notify the Plaintiff of the specific details of calculation of acquisition tax, additional tax, etc.

C. Accordingly, on July 8, 2016, the Defendant revoked each of the above dispositions during the instant lawsuit, and issued each disposition imposing acquisition tax of KRW 1,685,930 (including additional tax) and KRW 168,590 (including additional tax) on the Plaintiff on July 8, 2016, stating the details of calculation of acquisition tax, additional tax, etc.

(hereinafter “Disposition in this case”). [Grounds for recognition] The Disposition in this case is without dispute; Gap evidence Nos. 1, 2, 3; Eul evidence Nos. 1 through 5; and the purport of the whole pleadings.

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) is not a standing timber but a raw timber to be acquired in substance through the instant contract. In light of the content of the instant contract and the purport of the relevant statutes, the subject matter of the instant contract ought to be deemed as a raw timber, not a standing timber. Therefore, the instant disposition premised on the Plaintiff’s acquisition of standing timber is unlawful and is also in violation of the substance over form principle. 2) Even if the Plaintiff acquired standing timber, the instant disposition is unlawful for the following reasons. The Local Tax Act prescribed that the acquisition of standing timber is subject to acquisition tax.