1. Acquisition tax imposed by the Defendant on March 23, 2015 on the Plaintiffs, KRW 51,982,680, local education tax 4,794,260, and special rural development tax 2.

1. Details of the disposition;

A. On November 7, 2012, the Plaintiffs purchased D 362 square meters and facilities for the elderly (hereinafter “each of the instant real property”) on the third floor of reinforced concrete structure on the land (hereinafter “each of the instant real property”) from Namyang-si, Namyang-si, and completed the registration of ownership transfer for each of the instant real property on January 2, 2013.

B. The Defendant, pursuant to Article 19(1) of the former Restriction of Special Local Taxation Act (amended by Act No. 12955, Dec. 31, 2014; hereinafter the same) on the ground that the Plaintiffs acquired each of the instant real estate to establish and operate a childcare center, granted the Plaintiffs reduction of acquisition tax, special rural development tax, local education tax, etc. (hereinafter “acquisition tax, etc.”) due to the acquisition of each of the instant real estate.

C. The Plaintiffs closed the pertinent childcare center on April 13, 2014 while operating the E childcare center in each of the instant real estate.

On March 23, 2015, the Defendant imposed acquisition tax of KRW 51,982,680, local education tax of KRW 4,794,260, special rural development tax of KRW 2,195,130, which was reduced or exempted for each of the instant real estate on the grounds that the Plaintiffs used each of the instant real estate for other purposes when the period of direct use thereof was less than two years (hereinafter “instant disposition”).

[Reasons for Recognition] Each entry of Gap evidence Nos. 1, 4, Eul evidence Nos. 1 through 3, and 6 (including branch numbers), and the purport of the whole pleadings

2. In a case where a person who acquired real estate for the purpose of establishing and operating a child-care center alleged by the plaintiffs, leases the real estate to a third party and causes the third party to establish and operate a child-care center, it shall be deemed that the case constitutes “direct use” under Article 178 subparag. 2 of the Restriction of Special Local Taxation Act. The plaintiffs acquired each of the instant real estate on January 2, 2013 and lost their ownership on January 16, 2015.