A. The Plaintiff is a real estate investment company established for the purpose of acquiring, managing, disposing of, or leasing real estate pursuant to the Real Estate Investment Company Act. On December 20, 2013, the Plaintiff entered into a contract to purchase B B 606 Dong 1602 (hereinafter “instant house”) from A in the original city, and completed the registration of ownership transfer for the instant house in the name of the Plaintiff on January 7, 2014.

B. Upon entering into a sales contract for the instant housing, the Plaintiff entered into a sales contract with the condition that the instant housing be leased at KRW 100 million and KRW 310,000 per month to A, who is the seller, for five years. From January 2014, A had occupied the instant housing and resided in at the time of paying monthly rent. However, on April 28, 2014, A applied for the termination of the said lease contract to the Plaintiff on the ground that A had a rental fee burden and personal conditions, etc., and accordingly, the said lease was terminated.

C. In acquiring the instant housing, the Plaintiff was exempt from acquisition tax and local education tax pursuant to Article 34(4) and (5) of the Restriction of Special Local Taxation Act, and the Defendant provided that the Plaintiff shall pay acquisition tax and local education tax exempted to the Plaintiff on the grounds that “the period of lease for the instant housing does not meet at least five years due to the termination of the lease contract as above, causing additional collection under the proviso to Article 34(4) of the Restriction of Special Local Taxation Act,” and the Plaintiff reported and paid acquisition tax and local education tax for the instant housing, and KRW 1,658,490, local education tax and KRW 165,840,00.

On March 18, 2015, the Plaintiff asserted that “A’s failure to comply with the lease period due to the personal circumstances, etc. of A, a lessee, does not fall under grounds for additional collection under the proviso to Article 34(4) of the Restriction of Special Local Taxation Act” and filed a request for correction with the Defendant seeking a reduction of the total amount of the tax payable, but the Defendant rejected the Plaintiff’s request for correction on March 27,

hereinafter referred to as "the case."