1. Revocation of a judgment of the first instance;

2. Acquisition tax of 18,708,480 won, local education tax of the Plaintiff on May 1, 2013 and 1,731.

1. The court's explanation concerning this part of the disposition is the same as the corresponding part of the judgment of the court of first instance (from No. 5 to No. 31). Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act, the main sentence of Article 420 of the Civil Procedure Act.

2. Whether the instant disposition is lawful

A. The plaintiff's assertion concerning this part is identical to the corresponding part of the judgment of the court of first instance except for the following matters. Thus, this part of the plaintiff's assertion is accepted by Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

The following shall be added to the 4th page 12:

4) In light of the circumstances leading up to the amendment of Article 120(1)9 of the New Act, etc., the part of the penalty tax in this case’s disposition is unlawful.

5) The instant disposition is unlawful since the duty payment notice concerning the instant disposition was partially omitted in matters required by relevant Acts and subordinate statutes, and thus, the instant disposition was unlawful.

B. The content of this part of the pertinent law by the court is identical to the corresponding part of the judgment of the court of first instance (9-10 pages). Thus, this part is cited by Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

C. 1) As to the assertion of reduction or exemption of acquisition tax pursuant to the interpretation of Article 120(1)9 of the former Act, Articles 120(1)12 and 119(1)13 of the former Act (hereinafter “former Act”).

A special purpose company provides that "50/100 of acquisition tax shall be reduced or exempted for real estate acquired by a special purpose company by December 31, 2012 when it takes over securitization assets from the originator or another special purpose company, or manages, operates, or disposes of the acquired securitization assets, in accordance with an asset-backed securitization plan."