A. A. N&C Co., Ltd. (hereinafter “S&C”) did not pay value-added tax of KRW 221,863,620 in total as of March 2017, and wage and salary income tax and corporate tax (the due date for payment from September 30 to December 31, 2015: additional dues, etc.).

B. On February 13, 2017, the director of the tax office affiliated with the Plaintiff attached the amount up to the date of the above delinquent amount (including the increased additional dues added thereto) out of the current or future sales claims against the Defendant of the non-party company based on the above delinquent national tax and additional dues amounting to KRW 244,251,260 against the non-party company. On March 14, 2017, the notice of attachment was served to the Defendant on March 14, 2017. The above notice was served to the Defendant on March 16, 2017.

C. Meanwhile, at the time of the notification of the above attachment, the non-party company held a claim for waste treatment of KRW 132 million against the defendant and for on-site management service costs.

[Reasons for Recognition] Facts without dispute, Gap evidence Nos. 1 through 4, 7, Gap evidence No. 9-1 and 2, the purport of the whole pleadings

2. Where a claim is seized by the head of a tax office in accordance with the procedure for disposition on default under the National Tax Collection Act, the obligor of the seized claim may not repay the obligation to the obligee. Meanwhile, where the head of a tax office subrogates the obligee by notifying the obligor of the seized claim under Article 41(2) of the National Tax Collection Act, the head of a tax office shall be deemed to have acquired the right to collect the claim. Thus, when the due date comes to the due date, the obligor of the seized claim shall be liable

In light of the above legal principles, on March 30, 2017, after the date of arrival of the above notification of seizure, the Defendant repaid the above sales debt of KRW 132 million to the non-party company.

Even (Evidence A No. 7) cannot prevent the Plaintiff from filing the instant claim.

The defendant's claim against the plaintiff for KRW 132 million and the plaintiff's delivery date of the copy of the complaint of this case is obvious.