1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasons why the court should explain by the court of first instance are as follows, except for the Plaintiff’s addition of the judgment of the first instance, which is specifically emphasized or newly raised by this court, and thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. Judgment on the plaintiff's assertion

A. The Plaintiff’s assertion 1) The meaning of the terms used in the new Act and the new Act and the new Act are as follows. Article 120(1)9 of the former Act provides that acquisition tax shall be reduced by 50% for the acquisition of real estate acquired by a special purpose company by an asset holder under Article 2 subparag. 2 of the Asset-Backed Securitization Act or by another special purpose company on or before December 31, 2012 in accordance with an asset-backed securitization plan registered pursuant to Article 3 of the Asset-Backed Securitization Act. The term “acquisition” under the above provision does not mean that a special purpose company directly acquires the securitization assets acquired from an asset holder or another special purpose company (hereinafter “asset holder”) in the process of managing, operating, or managing the asset acquired from the asset holder, etc.., and it means that “a special purpose company, which manages, operates, or disposes of the asset acquired by the asset holder, etc. in accordance with an asset-backed securitization plan, shall be interpreted to mean that acquisition tax shall be reduced or exempted.