1. Acquisition tax of 68,520,290 won, local education tax of 6,422,940 won, and special rural development tax of 2,96.

1. Details of the disposition;

A. The Plaintiff is a company established on February 8, 2012 for the purpose of the business of manufacturing feed for fish farming, processing and storing aquatic animals, etc.

B. On January 31, 2012, the Plaintiff purchased land and buildings listed in the separate sheet from B (trade name: C; hereinafter referred to as “previous business operator”) on the attached list of real estate (hereinafter referred to as “instant real estate”), and completed the registration of ownership transfer on March 28, 2012.

At the time of acquiring the instant real estate, the Plaintiff filed an application for reduction or exemption of acquisition tax by deeming the acquisition of the property for business of a small or medium start-up start-up enterprise under Article 120(3) of the former Restriction of Special Taxation Act (amended by Act No. 11614, Jan. 1, 2013; hereinafter the same) as the acquisition of the instant real estate

C. On May 14, 2015, the Defendant conducted a tax investigation with respect to the Plaintiff. As a result, deeming that the Plaintiff’s previous entrepreneur runs the same kind of business as the business run in the instant real estate, the Plaintiff does not constitute a small and medium start-up start-up enterprise subject to acquisition tax reduction and exemption. On January 19, 2016, the Defendant issued a disposition to impose acquisition tax of KRW 68,520,290, local education tax of KRW 6,422,940, and special rural development tax of KRW 2,96,920, total of KRW 77,940,150,00.

(hereinafter “instant disposition”) D.

The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on April 6, 2016, but was dismissed on or around October 11, 2016.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 2, and 3 (including branch numbers; hereinafter the same shall apply), the purport of the whole pleadings

2. Determination on the legitimacy of the instant disposition

A. The main business operated by the Plaintiff’s main intent of the Plaintiff’s assertion is to remove the head, interior, sucker, sucker, and bones, etc. of fishery products so that consumers can prepare the fishery products immediately without loss, and sell the products for eating, processing, storing, and packing them.