The judgment of the court below is reversed, and the case is remanded to Daejeon High Court.

The grounds of appeal are examined.

1. As to the ground of appeal No. 1, Articles 120(1)12 and 119(1)13 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010) (hereinafter “former Provisions of the Special Taxation Act”) provide that “acquisition tax shall be reduced by 50/100 on real estate acquired by a special purpose company from an asset holder or another special purpose company, where the special purpose company takes over securitization assets from the asset holder or another special purpose company, manages, operates, or disposes of the acquired securitization assets by December 31, 2012.” However, Article 120(1)9 of the Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010) excluded from acquisition tax on real estate acquired by a special purpose company from the asset-backed securitization company or the special purpose company subject to abatement, exemption, or exemption from acquisition tax on real estate from the asset-backed investment company.”

In light of the language and structure of the aforementioned provision, and the amended special provisions of the Act on the Special Cases of Taxation on a special purpose company in order to reasonably coordinate the scope of special taxation on a special purpose company and promote the equity of taxation with general creditors, the “real estate acquired by a special purpose company in the management, operation, and acquisition of the acquired securitization assets in the case of management, operation, and acquisition” under the former Special Provisions of the same Act are deemed to be excluded from acquisition tax reduction and exemption. As such, the secured real estate acquired by a special purpose company in the auction procedure of real estate secured by a secured claim, which is securitized assets, by directly