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 July 2, 2013, the Plaintiff completed business registration under the Housing Construction and Sales Business Act, and closed business on December 31, 2014.

B. On August 30, 2013, the Plaintiff obtained a building permit to newly construct 12 households of multi-household housing (hereinafter “instant housing”) on the land outside Seoul Northern-gu, Seoul and one parcel (hereinafter “instant housing”). On September 9, 2013, the Plaintiff purchased the housing from the year 2014 after obtaining approval for use on December 27, 2013.

C. When the Plaintiff filed a return on comprehensive income tax for the year 2014, the Plaintiff filed a return on the amount of income less than the amount prescribed in Article 143(4)2(b) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 26067, Feb. 3, 2015; hereinafter the same) in 2013, which was the taxable period immediately preceding the 2014 taxable period, and calculated the estimated income by applying the simple expense rate under the above provision, and filed a return on and paid the comprehensive income tax by applying the special tax reduction and exemption for small and medium enterprises pursuant to Article 7(1) of the former Restriction of Special Taxation Act (amended by Act No. 12853, Dec. 23, 2014; hereinafter the same).

As a result of the consolidated investigation of the Plaintiff, the head of the Seoul Regional Tax Office notified the Defendant of taxation data to the effect that: (a) the Plaintiff is a new entrepreneur who commenced business in 2014 in which the sales amount of the instant house was generated; (b) the amount of income exceeds the standard amount under Articles 143(4)1 and 208(5)2 of the former Enforcement Decree of the Income Tax Act; (c) the amount of income should be estimated by applying the standard expense rate rather than the simple expense rate; and (b) the Plaintiff did not engage in construction business; and (c) the Plaintiff notified the Defendant of taxation data to the effect that the special

E. On April 2, 2018, the Defendant issued a correction and notification of the global income tax of KRW 125,561,810 (including additional tax of KRW 36,83,679) to the Plaintiff for the year 2014.

hereinafter “instant disposition”.