2. The costs of lawsuit are assessed against the plaintiffs.

On January 30, 2015, the Plaintiffs purchased 1/4 shares of each of the above land and buildings (hereinafter “instant real estate”) at the Busan District Court Dong Branch E, and F real estate auction procedure at Busan Shipping Daegu G, Busan, 689m2 and its ground (the third floor underground of the steel framed reinforced concrete slab roof, the 11st floor neighborhood living facilities, business facilities, and the above land and buildings; hereinafter “instant real estate”) at KRW 6,730,000.

On November 17, 2015, the Plaintiffs: (a) the tax base is KRW 6,730,000,000 of the total purchase price of the instant real estate to the Defendant; and (b) Article 11(1)7(b) of the Local Tax Act.

By applying 40/1,00 of the acquisition tax rate under the item, acquisition tax amounting to KRW 269,20,000, special rural development tax amounting to KRW 13,460,00, and local education tax amounting to KRW 26,920,00,000.

On July 12, 2018, the Plaintiffs filed a claim for correction stating that the real estate acquired by an auction to the Defendant constitutes original acquisition by applying 28/1,000 of the acquisition tax rate under Article 11(1)3 of the Local Tax Act, including acquisition tax, which was already reported and paid, shall be refunded KRW 96,921,00,00, out of the total amount of KRW 309,580,580,000 (hereinafter “instant claim for correction”).

On September 4, 2018, the Defendant rejected the Plaintiffs’ claim for correction on the ground that the acquisition of real estate by auction constitutes acquisition by succession rather than original acquisition by succession.

(hereinafter “instant disposition”). The Plaintiffs appealed and filed an administrative appeal with the Tax Tribunal on November 28, 2018, but the Tax Tribunal dismissed the Plaintiffs’ claim on March 11, 2019.

[Ground of recognition] Fact that there is no dispute, Gap evidence 1 or Gap evidence 4 (including branch numbers), and the plaintiffs' assertion of the purport of the whole argument as to the purport of the argument by the plaintiffs, the plaintiffs' assertion as to the purport of the whole argument, are acquired by a successful bid during a voluntary auction procedure, and Article 11 (1) 7b of the Local Tax Act is based on the premise that

applying 40/100 of the acquisition tax rate under the item.