1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. The reasoning of the court’s explanation of this case is as stated in the reasoning of the judgment of the first instance except for dismissal or addition of the judgment of the first instance as follows. Thus, this is accepted in accordance with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

The second half to nine of the judgment of the first instance court added "2,350 households" to "2,350 households of the second half of the judgment of the first instance court" (hereinafter "the apartment of this case") after adding "the second half of the judgment of the first instance court" to "the second half of the second half of the judgment of the second instance court," and "the fourth half of the judgment of the first instance court "the other construction costs of this case 4,701,029,116 won" was added to "the other construction costs of this case 4,701,029,116 won" and "the other construction costs of this case 684,478,937 won of the other construction costs of the apartment of this case among the acquisition prices already reported by the plaintiff, and other construction costs of this case 351,928,361 won of the land of this case excluding the above construction costs of this case 4,701,029,116 won," and "the other construction costs of this case 361,6381." were added to the tax base below.

2. Judgment on the main defense of this case

A. On November 10, 2014, the Defendant’s assertion that the Plaintiff sought revocation of the tax amount equivalent to KRW 684,478,937 reduced out of the cost for new construction of the instant apartment that was initially filed and paid to the Plaintiff in excess of the amount of the tax payment notice, and KRW 351,928,361 reduced out of the cost for land category change of the instant land. However, the said tax amount cannot be claimed for revocation because it becomes impossible to bring an objection after the lapse of three years from the period of objection or the statutory due date of return, as such, the said tax amount cannot be claimed for revocation.

B. Article 36(1) of the Framework Act on Local Taxes provides that local tax-related laws.