1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. On March 9, 2010, the Plaintiff acquired securitization assets in KRW 179.9 billion from the asset holder to a special purpose company established pursuant to Article 2 subparagraph 5 of the Asset-Backed Securitization Act, and from the asset holder on March 30, 2010, securitization assets including loan claims secured by the Gangnam-gu Seoul apartment 705-dong 706 (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 received the decision to permit the sale of the instant real estate as the purchaser on February 23, 2012, and paid the sale price on April 12, 2012.

C. On May 8, 2012, the Plaintiff reported and paid acquisition tax of KRW 18 million and KRW 1.8 million for local education tax, calculated by reduction of 50/100 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”) on the basis of acquisition value of the instant real estate as the tax base to the Defendant.

On April 9, 2013, the Defendant: (a) deemed that the acquisition of the instant real estate does not fall under those subject to reduction or exemption of acquisition tax under the former Act; (b) rendered a disposition imposing acquisition tax of KRW 23,236,200, and local education tax of KRW 25,379,820 (hereinafter “instant disposition”).

[Ground of recognition] Facts without dispute, Gap evidence 1, Eul evidence 1-1-4, Eul evidence 2-1-2, Eul evidence 2-5, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion 1 of the former Act reduced the acquisition tax by 50/100 on real estate acquired by a special purpose company until December 31, 2012. The new Act reduced the scope of reduction and exemption so as to apply only to real estate acquired from an originator or another special purpose company by December 31, 2012.

On the other hand, Article 52 of the Addenda to the new law is in accordance with the previous provisions at the time this Act enters into force.