1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. From August 28, 2008, the Plaintiff operated a convalescent hospital with the trade name of “Cvalescent Hospital” in the Namyang-si B (hereinafter “Cvalescent Business”) from Namyang-si, Namyang-si, and the Plaintiff is operating a convalescent hospital with the trade name of “E Hospital” from November 7, 2012.

B. On the other hand, on April 8, 2011, the Plaintiff entered into a contract to purchase the F site and building (hereinafter “instant real estate”) from the Glulus Slusk National Oil Co., Ltd. (hereinafter “Blusk National Oil”), for KRW 8.5 billion (hereinafter “instant sales contract”), and paid the down payment of KRW 5.5 billion on the day of the contract, and the intermediate payment of KRW 5.7 billion on April 22, 201, the Plaintiff agreed to pay the remainder of KRW 2.3 billion after 12 months from the contract date.

C. On April 22, 2011, Blusk’s tables did not receive the intermediate payment, and notified the Plaintiff of the forfeiture of the down payment.

Although the Plaintiff filed a lawsuit claiming the return of down payment, the judgment dismissing all the Plaintiff’s claims on April 27, 2012 was rendered (Seoul Western District Court Decision 201Gahap8188 Decided April 27, 2012), and the above judgment became final and conclusive around that time.

The Plaintiff filed a comprehensive income tax return in 2012 by including KRW 500 million (hereinafter “the down payment to be confiscated”) to the necessary expenses incurred in the process of acquiring fixed assets for business in order to move the existing hospital.

E. The Defendant, on the ground that the instant contract deposit cannot be deemed to have contributed to forming the amount of business income, did not include necessary expenses, and corrected and notified the global income tax of KRW 196,935,170 as of October 1, 2013.

(hereinafter referred to as “instant disposition”). The Plaintiff filed an appeal with the Tax Tribunal on March 14, 2014, but the decision of dismissal was rendered on June 27, 2014.

[Ground of recognition] Facts without dispute, Gap evidence 2, 4, 7 through 9, Eul evidence 1 and 2, the purport of the whole pleadings

2. This.