A. On or before January 1, 2014, before the enforcement date of the Local Tax Act (amended by Act No. 12153, Jan. 1, 2014; hereinafter “former Local Tax Act”) amended by the company engaging in real estate trust business, etc., the Plaintiff Incorporated Real Estate Trust Co., Ltd. (hereinafter “Plaintiff Trust Company”) entered into a real estate trust agreement under the Trust Act with respect to each real estate indicated in the “name” column in the “property tax, etc. list” among the attached Table 1 “property tax, etc.” (hereinafter “instant trust agreement”; hereinafter “instant trust property”). The trust registration of the instant trust property is completed.

B. Plaintiff U.S. U.S. Ethpppppp (hereinafter “Plaintiff U.S. Ethppppppppp”) is the first pledgee of the right to benefit from trust and preferential right to benefit under the instant trust agreement (the right to preferential repayment of the principal and interest, etc. within the scope of the remaining amount obtained by subtracting the costs of trust affairs, trust remuneration, etc. from the proceeds from the sale of trust assets).

C. Pursuant to Article 107(1)3 of the amended Act (hereinafter “instant property tax provision”) and the main sentence of Article 1 and Article 17(1) of the Addenda, the Defendant imposed and notified, respectively, KRW 152,90,120 on the Plaintiff trust company, the trustee of the instant trust property, each of the property tax, etc. indicated on the list of “property, etc.” attached Table 1 on July 16, 2014, including each of the property tax, etc. indicated on the “list of Property, etc.” on September 10, 2014.

(hereinafter referred to as “instant Disposition 1” and “instant Disposition 2” in the disposition of imposition as of July 16, 2014, and as of September 10, 2014, each of the above dispositions is collectively referred to as “instant Disposition 2.” [The grounds for recognition], without dispute, and the number of evidence Nos. 1 and 2 is numbers.