1. Acquisition tax imposed on the Plaintiff on May 10, 2013 by the Defendant, 21,542,40 won, local education tax 1,984,240 won, and agricultural special tax 907.

1. Details of the disposition;

A. On March 8, 2011, the Plaintiff was a special purpose company established pursuant to Article 2 subparagraph 5 of the Asset-Backed Securitization Act, and acquired, from the asset holder on March 29, 201, securitization assets containing loan claims of KRW 128.2 billion, which are included in loan claims against the asset holder, which are secured by the riverwon-gun-gun, Crossing-gun, Crossing-do, 427-1 and one parcel and its ground buildings (hereinafter “instant real estate”).

B. On June 11, 2012, the Plaintiff directly participated in the auction procedure on the instant real estate in order to recover the above loan claims, and won the instant real estate at the auction on June 11, 2012, and paid in full the sale price on July 30, 2012.

C. On October 15, 2012, the Plaintiff reported and paid acquisition tax, local education tax, and special tax for rural development (hereinafter “acquisition tax, etc.”) that reduced or exempted 50/100 of the tax amount pursuant to Article 120(1)12 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter “former Act”) with respect to the acquisition of the instant real estate to the Defendant.

On May 10, 2013, the Defendant: (a) deemed that the acquisition of the instant real estate does not constitute subject to reduction or exemption of acquisition tax under the former Act; (b) rendered a disposition imposing acquisition tax on the Plaintiff (hereinafter “instant disposition”) on the sum of KRW 24,43,760 (i.e., KRW 21,542,40, KRW 1,984,240, KRW 900, KRW 243,760 (i.e., KRW 21,542, KRW 400).

[Ground of recognition] Facts without dispute, Gap evidence No. 1, Eul evidence No. 4 (including virtual number), and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The gist of the Plaintiff’s assertion 1) is that procedural errors exist, and the tax payment notice (No. 1; hereinafter “instant tax notice”) regarding the instant disposition does not properly state the basis for calculating the amount of acquisition tax, special tax for rural development, and local education tax (hereinafter “acquisition tax, etc.”). Therefore, the instant disposition is subject to the disposition.