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. Details of the disposition;

A. B, on February 13, 2009, in order to convert a personal place of business operated by himself/herself into a corporation with the trade name “A”, the assets used for business including land and buildings at the above place of business (the net asset value of KRW 2,088,079,167 as a result of appraisal) were invested in kind in the Plaintiff, who became the promoters

On February 20, 2009, the Plaintiff was established as KRW 2,100,00,000 (the total number of shares issued, KRW 210,00,000, the face value of KRW 10,000). B acquired 208,807 out of the total number of shares issued by the Plaintiff.

B. The Plaintiff was exempted from acquisition tax, special rural development tax, registration tax, and local education tax pursuant to Articles 119(4) and 120(5) of the former Restriction of Special Taxation Act (amended by Act No. 9671, May 21, 2009; hereinafter the same) with respect to the above acquisition on February 20, 209 upon investment in kind.

C. On August 20, 2012, the Defendant investigated the Plaintiff’s place of business, and confirmed the omission in the assets invested in kind at the time of an appraisal for investment in kind, even though the portion of the building without permission equivalent to KRW 106,135,500 (hereinafter “instant building”) was in fact an investment in kind.

The Defendant imposed an assessment of KRW 2,194,214,667 on November 13, 2012, on the ground that the Plaintiff’s capital KRW 2,100,000 after investment in kind falls short of the net asset value of the Plaintiff’s individual workplace B, which includes the building portion of the instant building (i.e., net asset value of KRW 2,08,078,079,079,079, the net asset value of the instant building (i.e., the net asset value of KRW 106,135,50) and the acquisition of the Plaintiff’s business assets does not fall under the requirements for exemption from acquisition tax, etc. under Articles 119(4) and 120(5) of the former Restriction of Special Taxation Act. On November 13, 2012, the Defendant imposed an assessment of KRW 80,834,460, special rural development tax, KRW 9,364,370, KRW 88,4250

(hereinafter referred to as “instant disposition”). [Grounds for recognition] without dispute, Gap evidence 4-1, 2, 5-1 through 7, 5-2.