1. The part of acquisition tax imposed by the Defendant against the Plaintiff on June 11, 2013, which was KRW 2,787,300, and local education tax.

1. Details of the disposition;

A. On March 8, 2011, the Plaintiff was a special purpose company established pursuant to Article 2 subparag. 5 of the Asset-Backed Securitization Act, and acquired, on March 29, 201, securitization assets, including loans secured by 115-31, 115-32, 115-33, 115-35 land and 115-31 ground buildings (hereinafter “instant real estate”), from the Industrial Bank of Korea, the asset holder of the Ganpo-si, Kimpo-si, Kimpo-si.

B. In order to recover the above loan claims, the Plaintiff directly participated in the auction procedure for the instant real estate, and received the decision to permit the sale of the instant real estate on December 1, 201, and paid in full the sale price on January 9, 2012.

C. On January 10, 2012, the Plaintiff reported and paid acquisition tax of KRW 19,00,000, totaling KRW 1,900,000, local education tax of KRW 1,900,000, and special rural development tax of KRW 950,00,000, calculated by reducing and exempting the tax amount of KRW 50/10 as the tax base of the instant real estate to the Defendant.

On June 11, 2013, the Defendant: (a) deemed that the acquisition of 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; (b) was amended by Act No. 11614, Jan. 1, 2013; hereinafter “new Act”); and (c) was not subject to acquisition tax reduction under Article 120(1)9 of the former Act (amended by Act No. 10406, Dec. 27, 2010; and (d) accordingly, imposed acquisition tax of KRW 21,787,30 (including additional tax of KRW 2,787,30), local education tax of KRW 2,178,730 (including additional tax of KRW 278,730), special rural development tax of KRW 1,089,360 (including additional tax of KRW 3605,39,505).

(hereinafter “Disposition in this case”). 【No dispute exists, Gap evidence 1, Gap evidence 2-1 through 5, Eul evidence 1 and 2, and the purport of the whole pleadings.

2. Whether the instant disposition is lawful

A. The plaintiff asserts that the disposition of this case is unlawful for the following reasons.

1. Interpretation of Article 120 (1) 9 of the new Act.