A. On June 22, 2010, the Plaintiff acquired securitization assets, such as collateral bonds of a new bank from a new bank in the amount of KRW 8.4 billion, from a special purpose company established under the Asset-Backed Securitization Act. On July 15, 2010, the said securitization assets include loan claims secured by B and three parcels outside the Gyeongsan City (hereinafter “instant real estate”).

B. In order to recover the above loan claims, the Plaintiff directly participated in the auction procedure on the instant real estate, and was awarded a successful bid on March 30, 201, and paid the price on May 30, 201.

C. As to the acquisition of the instant real estate, the Plaintiff reported and paid acquisition tax, local education tax, and special rural development tax (hereinafter “acquisition tax, etc.”) to the Defendant, for which 50/100 of tax amount was reduced or exempted pursuant to Article 120(1)12 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter “former Act”); and the amended Act on the same day (hereinafter “New Act”).

On April 12, 2013, the Defendant: (a) deemed that the acquisition of the instant real estate does not fall under those subject to reduction or exemption of acquisition tax under the former Act; (b) rendered a disposition imposing acquisition tax of KRW 20,000,000; (c) local education tax of KRW 2,000,000; and (d) special rural development tax of KRW 1,00,000,000 (hereinafter “instant disposition”).

[Ground of recognition] Facts without dispute, Gap evidence 1, Eul evidence 1, Eul evidence 5 through 7, the purport of the whole pleadings

2. The legality of disposition.

A. The Plaintiff’s tax notice on the instant disposition (hereinafter “instant tax notice”) states only the tax base of acquisition tax, the local education tax and special agricultural and fishing villages tax are not indicated. The tax base of each tax item is not indicated, and each tax item is not indicated, and only the taxable object is “public sale of a parcel of land other than B, 3812.00 square meters of land and three lots of land, 700 square meters of land and three lots of land,” and is classified by each parcel.