A. On November 29, 2011, the Plaintiff was a specialized securitization company established pursuant to the Asset-Backed Securitization Act, and acquired securitization assets, including loan claims secured by 208 Dong-dong 1117, Dong-dong 1117, Dong-dong 801 (hereinafter “instant real estate”) from the asset holder during Ansan-si period from the asset holder on December 2, 201.

B. In order to recover the above loan claims, the Plaintiff directly participated in the auction procedure of the instant real estate and paid the sales price thereof on June 19, 2012 after receiving a successful bid on the instant real estate on June 19, 2012.

C. After that, the Plaintiff’s tax base is 470,000,000 acquisition value of the instant real estate, and 50/100 of the tax amount under Article 120(1)12 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010) was reduced and exempted, thereby reporting and paying acquisition tax, local education tax, and special rural development tax.

On May 13, 2013, the Defendant rendered the instant disposition imposing acquisition tax of KRW 11,903,220, local education tax of KRW 1,096,320, and special rural development tax of KRW 501,160 on the Plaintiff on May 8, 2013, deeming that the instant real estate acquisition is not subject to reduction or exemption of acquisition tax under Article 120(1)9 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010).

[Ground of recognition] The entry of Gap evidence No. 1 and the purport of the whole argument

2. Whether the disposition is lawful;

A. The Plaintiff’s assertion was made upon the notice of tax payment, but only the tax base of the acquisition tax is specified in the said notice, and the local education tax is not specified in the tax base of the special rural development tax, but does not include each tax item’s tax rate.

In addition, the instant disposition seems to have been imposed by adding the principal tax and the additional tax, but it cannot be identified separately from the principal tax and the additional tax.

In addition, there was no advance notice of taxation.

Therefore, the instant disposition is procedurally unlawful.

(b).