A. On September 5, 201, the Plaintiff, a special purpose company established under the Asset-Backed Securitization Act, acquired securitization assets in KRW 72.7 billion, including loan claims secured by Goyangyang-gu Am. 704-dong 604 (hereinafter “instant real estate”) from the asset holder on September 29, 2011, as a special purpose company established under the Asset-Backed Securitization Act.

B. The Plaintiff directly participated in the auction procedure of the instant real estate in order to recover the above loan claims and was awarded a successful bid on February 15, 2012.

4. 24. The sales amount was paid in full.

C. On May 14, 2012, the Plaintiff reported and paid acquisition tax, local education tax, and special tax for rural development, calculated by deducting 50/100 from the tax base of acquisition tax amount of KRW 315,000,000 with respect to the instant real estate as the tax base.

On June 11, 2013, the Defendant: (a) deemed that the acquisition of the instant real estate was not subject to acquisition tax reduction or exemption pursuant to Article 120(1)9 of the Restriction of Special Taxation Act, which was amended by Act No. 10406, Dec. 27, 2010; (b) concluded that it was not subject to acquisition tax reduction or exemption pursuant to Article 120(1)9 of the same Act; and (c) imposed acquisition tax amounting to KRW 8,263,080, local education tax amounting to KRW 763,300, and special rural development tax amounting to KRW 350,150

(hereinafter “Disposition in this case”). [Grounds for recognition] The Disposition in this case is without dispute, Gap evidence 1, Eul evidence 1 to 4, and the purport of the whole pleadings.

2. Whether the instant disposition is lawful

(a) The details of the relevant statutes are as shown in the attached statutes;

B. According to the relevant legal principles and Articles 2(1)15 and 55(1) of the Framework Act on Local Taxes, and Article 36 of the Enforcement Decree of the Framework Act on Local Taxes, a local tax payment notice may be issued in cases of a taxpayer’s taxable year and items of the local tax to be paid, a taxpayer’s address, name, tax base, tax rate, tax rate, amount of tax, payment deadline, place of payment, measures to be taken in cases where the local tax was not paid by the payment deadline and measures to be taken