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 March 31, 2014, the Plaintiff, a company engaged in real estate rental business, etc. reported KRW 177,352,971 as corporate tax for the year 2013 portion, but the Busan regional tax office conducted a corporate tax investigation on the Plaintiff from May 29, 2014 to July 25, 2014, it deemed that the Plaintiff failed to report corporate tax on capital gains, such as land under Article 55-2 of the former Corporate Tax Act (Amended by Act No. 12166, Jan. 1, 2014; hereinafter “former Corporate Tax Act”).

From January 1, 2013 to December 31, 2013, the Plaintiff sold a total of 41,872 square meters of forest land (hereinafter “instant land”) owned by the Plaintiff, including the land, etc. 358-3, Cheongcheon-do, Seocheon-do, Ycheon-do, Ycheon-do, Chungcheongnamcheon-do. This constitutes the transfer of “non-business land” under Article 55-2(1)3 of the former Corporate Tax Act.

Therefore, the Plaintiff did not report the amount of KRW 893,331,432, which is the amount calculated by applying 30% of the tax rate as corporate tax at KRW 2,977,771,442 of capital gains on the instant land calculated in accordance with Article 55-2 (6) of the former Corporate Tax Act (hereinafter referred to as the “subner”).

B. On September 2, 2014, the Defendant notified the Busan regional tax office of the foregoing taxation data, issued a disposition imposing an additional amount of KRW 934,871,340 (= = 893,331,432 won + 41,539,911 won (additional tax), and less than KRW 10) on the Plaintiff (hereinafter “instant disposition”).

C. On November 18, 2014, the Plaintiff filed a tax appeal on the instant disposition, but received a decision of dismissal on February 27, 2015 ( notified on March 3, 2015) and filed the instant lawsuit on May 29, 2015.

On January 12, 2016, the Plaintiff applied for an adjudication on the unconstitutionality of laws under Article 55-2(6) of the former Corporate Tax Act, which set the standards for calculating the amount of corporate tax in this court, but was dismissed on April 20, 2016. The Plaintiff requested an adjudication on constitutional complaint on the said provisions to the Constitutional Court on May 9, 2016, but the said provision on November 30, 2017.