A. On November 24, 2011, the Plaintiff was a special purpose company established pursuant to the Asset-Backed Securitization Act, and acquired securitization assets including loan claims secured by the former A apartment 505-dong 403-dong 403 (hereinafter “instant real estate”) from the asset holder on December 2, 201, during the Ansan-si period from the asset holder.

B. In order to recover the above loan claims, the Plaintiff directly participated in the auction procedure of the instant real estate and received the instant real estate sale on August 14, 201 and paid the sales price in full on September 24, 201.

C. After that, the Plaintiff reported and paid to the Defendant acquisition tax, local education tax, and special rural development tax, calculated by deducting 50/100 from the tax base the acquisition tax amount of KRW 275,000 with respect to the instant real estate as the tax base.

On May 8, 2013, the Defendant issued the instant disposition imposing acquisition tax of KRW 6,895,350, local education tax of KRW 634,530, and special rural development tax of KRW 289,760 on the Plaintiff by deeming that the instant real estate was not subject to acquisition tax reduction under Article 120 (1) 9 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter “new Act”); and that it was not subject to acquisition tax reduction under Article 120 (1) 9 of the former Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter “former Act”).

[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, this case.