A. 1) B is to convert a business entity into a legal entity while engaging in the electronic application processing business, etc. under the trade name “D” in the UP, and on February 28, 2011, the common deposit amounting to KRW 901,493,822 among D’s assets (hereinafter “instant deposit”).

(1) The term “investment contract in kind” (hereinafter “instant investment contract”) with the Plaintiff (as of March 1, 201, 201) on the same day, with the content that on March 1, 2011, the Plaintiff (as of the date of establishment) would make investments in kind with the total amount of assets and liabilities on the D’s account books

(2) On September 22, 2011, the Plaintiff completed the registration of ownership transfer in the name of the Plaintiff with respect to land E and 8, E and 4 other than E and 3 lots of ground buildings and F (C) land (hereinafter “instant real estate”) according to the instant investment in kind, which are D’s assets, according to the instant investment in kind.

B. 1) The Plaintiff’s acquisition of ownership of the instant real estate on September 16, 201 by the former Restriction of Special Taxation Act (amended by Act No. 11133, Dec. 31, 2011; hereinafter the same shall apply)

(2) On January 9, 2014, the Defendant: (a) confirmed that the instant real estate was withdrawn; and (b) on the ground that “the Plaintiff’s capital fell short of the net asset value of DD calculated including the instant deposit, and does not meet the requirements for exemption from acquisition tax, etc. under Articles 120(5) and 32 of the former Restriction of Special Taxation Act” as the grounds for exemption from acquisition tax, etc. under Articles 120(5) and 32, imposed acquisition tax on the Plaintiff KRW 67,177,070, total amount of KRW 63,438,430,430 (hereinafter “instant disposition”).

3. On April 4, 2014, the Plaintiff is dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal.