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

On November 19, 2013, the registration of ownership transfer was made in the name C on the instant house, and on August 7, 2014, the registration of ownership transfer was made in the name of the Plaintiff.

Meanwhile, on the other hand, the Defendant: (a) issued a disposition of the preservation and seizure before the determination of national taxes, on August 6, 2014, on the grounds that the Defendant was found to have omitted the comprehensive income tax by filing a false return and that there was an act of evading national taxes in light of the property status,

(2) On November 4, 2014, the Plaintiff filed an objection with the Busan Regional Tax Office regarding the instant seizure, but was dismissed on November 27, 2014, and filed an appeal with the Tax Tribunal on February 27, 2015, but was dismissed on May 28, 2015.

On July 13, 2015, the Plaintiff requested the Defendant to release the instant seizure, but the Defendant respondeded that the said request cannot be accepted on July 23, 2015.

[Grounds for recognition] The Plaintiff asserted that: (a) the Plaintiff purchased the instant house from C on June 20, 2014 and paid all remainder on August 6, 2014; and (b) the Plaintiff was the actual owner of the instant house on the same day; (c) the Plaintiff was the owner of the instant house at the time of the instant seizure, not the Plaintiff; and (d) the Plaintiff was the bona fide purchaser who was unaware of C’s delinquency in tax payment at the time of the said purchase; and (e) the instant seizure was unilaterally conducted without confirmation as to the amount of tax payment as well as payment as to whether it was paid.

The defendant asserts that the plaintiff has no standing to seek the revocation of the attachment disposition of this case, and thus, the defendant is owned by the taxpayer for the purpose of collecting taxes.