A. Plaintiff KF Real Estate Trust Co., Ltd. (hereinafter “Plaintiff KF Real Estate Trust”) concluded a real estate trust agreement under the Trust Act (hereinafter “instant trust agreement”) with respect to each real estate indicated in the “name” column in attached Table 1 attached hereto with a company engaging in real estate trust business, etc. on or before January 1, 2014, which was the enforcement date of the Local Tax Act (amended by Act No. 12153, Jan. 1, 2014; hereinafter “former Local Tax Act”); and completed the trust registration of the instant trust property.

B. The Plaintiff UPS Specialized in Asset-Backed Securitization (hereinafter “Plaintiff Special Purpose Company”) is a preferential beneficiary under the instant trust agreement (the beneficiary is entitled to receive preferential payment of the principal and interest within the scope of the remaining amount obtained by subtracting the disposal cost, trust remuneration, etc. from the proceeds of the sale of trust assets from the proceeds of the sale of trust assets and the claims of the senior right holder) from the company established for the purpose of acquiring or transferring claims, security rights, and other property

C. Pursuant to Article 107(1)3 of the amended Act, the main sentence of Article 1 and Article 17(1) of the Addenda (hereinafter collectively referred to as the “instant Addenda provisions”), the Defendant, as indicated in the separate sheet No. 1, July 10, 2014, with respect to the Plaintiff’s non-real estate trust, the trustee of the instant trust property, as indicated in the separate sheet No. 1, as to the instant trust property.

9. 10. Each disposition on imposition of property tax was made as shown in the separate sheet No. 2.

(hereinafter “Disposition in this case”). / [Ground for recognition] The fact that there is no dispute, Gap evidence 1, Eul evidence 1-1 and 2, and the purport of the whole pleadings.

2. The provisions of the Local Tax Act that determine the person liable to pay property tax on the plaintiffs' alleged trust property as a truster for about 20 years after it was newly established on December 27, 1993.