1. Acquisition tax imposed on the Plaintiff on May 8, 2013 by the Defendant, 7,746,90 won, local education tax of KRW 712,690, and special rural development tax of KRW 325.

1. Details of the disposition;

A. On March 8, 2011, the Plaintiff was a special purpose company established pursuant to Article 2 subparag. 5 of the Asset-Backed Securitization Act, and acquired, on March 29, 201, securitization assets including loan claims secured by Pyeongtaek-dong 126-1 and 933 (hereinafter “instant real estate”) from the asset holder at Ansan-si (hereinafter “instant real estate”), around KRW 128.2 billion.

B. In order to recover the above loan claims, the Plaintiff directly participated in the auction procedure of the instant real estate and subsequently sold the instant real estate on August 14, 201 and paid the sales price in full on September 24, 201.

C. After that, the Plaintiff reported and paid to the Defendant acquisition tax, local education tax, and special rural development tax, calculated by deducting 50/100 from the tax base the acquisition value of the instant real estate as the tax base of KRW 310,000,000.

On May 8, 2013, the Defendant: (a) deemed that the acquisition of the instant real estate was not subject to acquisition tax reduction under Article 120(1)9 of the former Restriction of Special Taxation Act (amended by Act No. 10406, Dec. 27, 2010; (b) was amended by Act No. 11614, Jan. 1, 2013; hereinafter “new Act”); and (c) was not subject to acquisition tax reduction under Article 120(1)9 of the former Act (amended by Act No. 10406, Dec. 27, 2010; hereinafter “former Act”); and (d) imposed acquisition tax,746,90, local education tax, KRW 712,690, KRW 325,340, and KRW 8,784,930 (including additional tax) on the Plaintiff.

(hereinafter “Disposition in this case”). [No dispute exists on the ground of recognition], Gap evidence No. 1, Eul evidence No. 1, and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion was made upon the notice of tax payment, but only the tax base of the acquisition tax is specified in the said notice, and the local education tax is not specified in the tax base of the special rural development tax, but does not include each tax item’s tax rate.

In addition, the instant disposition is imposed by adding the principal tax and the additional tax.