1. Acquisition tax of 63,900,000 won, local education tax of 5,890,000 won, and special rural development tax of 63,90,000 won, which the Defendant paid to the Plaintiff on May 10, 2013.

1. Details of the disposition;

A. The Plaintiff, a special purpose company established pursuant to the Asset-Backed Securitization Act on November 29, 201, acquired securitization assets in KRW 269.9 billion from the Industrial Bank of Korea, the asset holder of which, on December 20, 201, the Plaintiff acquired securitization assets in KRW 2,69.9 billion, including loan claims secured by the Industrial Bank of Korea (hereinafter “instant real estate”).

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 on July 26, 2012, and paid the sales price in full on August 23, 2012.

C. On August 27, 2012, the Plaintiff reported and paid acquisition tax, local education tax, and special tax for rural development by reducing or exempting 50/100 of the tax amount pursuant to 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 Act”) on the basis of acquisition value of the instant real estate as the tax base of KRW 2.5 billion.

On May 10, 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, and imposed acquisition tax of KRW 63,90,000 on the Plaintiff, local education tax of KRW 5,890,00, and special rural development tax of KRW 2,695,000 (including additional tax) on the Plaintiff.

(hereinafter “Disposition in this case”). [Grounds for recognition] The Disposition in this case is without dispute, Gap evidence 1, Eul evidence 1 through 4 (including paper numbers) and the purport of the whole pleadings.

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1) Allied Asset Management Co., Ltd., which established the Plaintiff in violation of the principle of trust protection (hereinafter “Allied Asset Management”).

Even if the new law is applied from the Seoul Special Metropolitan City Treasury Tax Department, a special purpose company shall respond to an auction in the course of managing and operating the right to collateral on the basis of the claims acquired from the originator.