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 January 24, 2013, the Plaintiff entered into a contract with A (hereinafter referred to as “A”) and B (hereinafter referred to as “B on the purchase agreement with respect to the unsold housing unsold in lots, 347 households (hereinafter referred to as “instant unsold apartment”) in Suwon-gu, Suwon-gu, Seoul (hereinafter referred to as “instant apartment”) under which the Plaintiff purchased the unsold apartment in lots (hereinafter referred to as “instant unsold apartment”) under the resale agreement, and completed the registration of ownership transfer on April 29, 2013 with respect to the unsold apartment in lots.

B. As the Plaintiff’s head office of the Yeongdeungpo District Tax Office moved in around 2014, the Plaintiff classified the instant unsold apartment units as taxable objects, and filed a comprehensive real estate holding tax for the year 2013 (the base date for taxation) and the comprehensive real estate holding tax for the year 2014 (the base date for taxation) (the comprehensive real estate holding tax for the year 2013), the comprehensive real estate holding tax for the year 2014 (the base date for taxation), and the comprehensive real estate holding tax for the year 2014 (the total real estate holding tax for the year 2013), the special rural development tax for the year 1,493,718,840, the comprehensive real estate holding tax for the year 2014 for the year 3,922,9,146, the comprehensive real estate holding tax for the year 2014 for the year 2014).

C. On August 14, 2017, the Plaintiff: (a) on the ground that the instant unsold apartment is included in the scope of unsold housing units under Article 8(2)2 of the former Gross Real Estate Tax Act (Amended by Act No. 12153, Jan. 1, 2014); (b) Article 4(1)3(a) of the former Enforcement Decree of the Gross Real Estate Tax Act (Amended by Presidential Decree No. 25208, Feb. 21, 2014); and (c) Article 4 subparag. 1 of the Enforcement Rule of the Gross Real Estate Tax Act (Amended by Ordinance of the Ministry of Strategy and Finance No. 355, Jun. 28, 2013; hereinafter “instant provision”) that “The instant unsold apartment unit is exempt from comprehensive real estate tax, which is included in the scope of unsold housing units under Article 4 subparag. 1 of the Enforcement Rule of the Gross Real Estate Tax Act (Amended by Presidential Decree No. 25208, Feb. 21, 2014>