1. The plaintiff's claim is dismissed.

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

1. Details of the disposition;

A. The Plaintiff is a company that was divided and established in the Republic of Korea on March 31, 2009.

B. The registration of ownership transfer was completed on April 30, 2009 in the name of the Plaintiff on the ground of the corporate division on March 31, 2009 with respect to 23,801.4 square meters (hereinafter “instant land”) in Gangseo-gu Busan Branch Office, Gangseo-gu, Busan, which is owned by the Fire Institute Co., Ltd. (hereinafter “instant land”).

C. On April 28, 2009, the Plaintiff filed an application for local tax reduction or exemption and did not pay each tax stated in the purport of the application on the ground that the Plaintiff acquired the instant land due to a corporate division satisfying the requirements under each subparagraph of Article 46(1) of the Corporate Tax Act.

After conducting a tax investigation on October 20, 2010, the Defendant imposed acquisition tax of KRW 103,530,710, special rural development tax of KRW 103,53,05,05,040 on the ground that the Plaintiff acquired the instant land and did not continue the business succeeded from the divided corporation until the end of the business year which belongs to the registration date of the division, on the grounds that the Plaintiff did not continue the business succeeded from the divided corporation until the end of the business year which belongs to the registration date of the division.

E. On February 22, 2011, the Plaintiff filed a request for pre-assessment review, and the head of Busan Metropolitan City was non-adopted on March 22, 2011, and both the Plaintiff’s objection and the request for tax trial were dismissed.

[Reasons for Recognition] Uncontentious Facts, Gap 1-5 evidence, Eul 1-1-4 evidence, the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion 1) The Plaintiff continued to conduct the business by succession from the Plaintiff to the last day of the business year to which the registration date of the division belongs, and thus, the instant disposition is unlawful as it misleads the factual basis, and is unlawful. 2) The instant disposition, which retroactively collected the amended Act despite that there was no additional collection provision under the Act on Special Cases concerning Tax Restriction at the time of reduction

B. The details of the relevant statutes are as shown in the attached statutes.

C. Summary of reduction 1

Determination as to whether it constitutes a case.