1. Revocation of a judgment of the first instance;

2. Acquisition tax of the Defendant against the Plaintiff on April 9, 2013, KRW 149,000,000, and additional tax of KRW 49.

1. Details of the disposition;

A. On November 10, 2010, the Plaintiff acquired securitization assets including loan claims secured by Gwanak-gu in Seoul Special Metropolitan City (hereinafter “instant real estate”) from the asset holder on November 30, 201 to a special purpose company established pursuant to Article 2 subparag. 5 of the Asset-Backed Securitization Act, and from the asset holder on November 30, 2010, KRW 58.8 billion.

B. In order to recover the above loan claims, the Plaintiff directly participated in the auction procedure of the instant real estate and was decided to permit the sale of the instant real estate as the purchaser on September 6, 201, and completely paid the sale price on November 16, 201.

C. On December 7, 2011, the Plaintiff reported and paid acquisition tax of KRW 149 million, special rural development tax, KRW 7450,000,000,000,000,00 to the Defendant, calculated by reduction of tax amount of 50/100 pursuant to Article 120(1)12 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter “former Special Provision Act”) with respect to the instant real estate as the tax base on KRW 7.45 million.

Accordingly, on April 9, 2013, the Defendant 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 Special Provision Act, and issued a disposition imposing acquisition tax of KRW 149 million, additional tax of KRW 49,512,700, local education tax of KRW 18,361,270, and special rural development tax of KRW 9,925,630, and KRW 226,79,600 (hereinafter “instant disposition”).

[Reasons for Recognition] Facts without dispute, Gap evidence 1, Eul evidence 1-2, Eul evidence 1-2, Eul evidence 2-1 and Eul evidence 2-2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

(a) as shown in the Attachment of the relevant statutes;

B. Whether the provision on reduction or exemption of acquisition tax is applied to the acquisition of the instant real estate (1) The former Act on Special Cases Concerning Special Cases Concerning Special Cases Concerning Special Cases Concerning Special Cases Concerning Special Cases Concerning Real Estate acquired by a special purpose company until December 31, 2012, reduced by 50/100, and the amended special purpose law is amended.