1. The acquisition tax assessed against the Plaintiff on February 9, 2018 and the special rural development tax amount of KRW 91,173,600 and KRW 7,67,360, respectively.

1. Details of the disposition;

A. On August 8, 2016, the Plaintiff completed each registration of ownership transfer based on sale on August 5, 2016, as a company that runs real estate sales business and real estate leasing business, and as to housing units with a size of 539 square meters and its ground.

(hereinafter referred to as the “instant real estate” in total of the above land and housing

On August 5, 2016, the Plaintiff reported and paid acquisition tax of KRW 18,00,000 and KRW 1,800,000 and the total amount of KRW 1,800,000 and the special rural development tax of KRW 21,60,00,00, calculated by applying the general tax rate (2%) stipulated under Article 11(1) of the Local Tax Act with respect to the acquisition of the instant real estate.

C. On February 9, 2018, the Defendant deemed that the instant real estate falls under “a villa” as stipulated under Article 13(5)1 of the Local Tax Act (a building for residence, used for recreation, rest, play, etc. without using it for the extended residence, and land attached thereto), and imposed KRW 98,850,960 in total, 98,850,960 (including additional taxes), which is calculated by applying the heavy tax rate (10%) under the said provision, on the Plaintiff, less the acquisition tax already paid by the Plaintiff.

(hereinafter “Disposition in this case”). 【No dispute exists, entry of Gap evidence Nos. 1 and 2, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff alleged that he/she purchased the instant real estate and possessed it as inventory assets around August 2016 to promote the sale and purchase of electric power resource housing, and the Plaintiff’s representative C (hereinafter “representative”) had resided in the instant real estate from October 2016 to October 2016.

Therefore, since the instant real estate is used for the permanent residential purpose of the representative director, it does not constitute a villa subject to acquisition tax. Therefore, the instant disposition, which was based on the premise that the instant real estate is a villa, should be revoked illegally.

(b) Appendix attached to the relevant legislation;