1. Acquisition tax assessed against the Plaintiff on July 16, 2014, KRW 127,096,890, and local education tax; KRW 10,134,790, which was assessed against the Plaintiff.

1. Details of the disposition;

A. On December 20, 201, the Plaintiff donated D buildings and land (hereinafter “instant real estate”) in Yangju-si, each of which is owned by B and C, the head of the Plaintiff, and one half each, and completed the registration of ownership transfer on December 21, 201.

B. The Plaintiff constitutes real estate acquired by a religious organization under Article 50(1) of the former Restriction of Special Local Taxation Act (amended by Act No. 11138, Dec. 31, 201; hereinafter the same) to use directly for the purpose of religious activities. The Plaintiff was exempted from acquisition tax, special rural development tax, and local education tax by applying for reduction or exemption from acquisition tax, etc. by the Defendant.

C. After that, the Plaintiff, B, and C (hereinafter “B, etc.”) concluded an agreement on April 23, 2012, following the cancellation of the instant gift agreement, the Plaintiff and B, and C (hereinafter “B, etc.”)’s objection to the instant real estate and the issue of the collateral security (the collateral security established in the future of the Bank and the Korea Exchange Securities Co., Ltd. reaches the maximum debt amount of KRW 2.5 billion) with respect to the instant real estate, and cancelled the registration of ownership transfer in the Plaintiff’s name on April 2

In around 2014, the Defendant conducted a fact-finding survey on the instant real estate, and as a result, the Plaintiff cancelled the registration of ownership transfer on the said real estate to B, etc., and confirmed that the Plaintiff was in use as a factory by leasing it from E, etc.

Accordingly, on July 16, 2014, the Defendant rendered the instant disposition imposing acquisition tax of KRW 127,096,890, local education tax of KRW 10,134,790, and special rural development tax of KRW 7,262,670, respectively, on the ground that the Plaintiff constitutes “cases of sale, donation, or use for other purposes, without using it directly for its original purpose for at least two years from the date of use” under the proviso to Article 50(1) of the former Restriction of Special Local Taxation Act.

E. The Plaintiff appealed and filed an appeal with the Tax Tribunal on October 13, 2014, but the appeal was dismissed on March 20, 2015.