A. B, on January 30, 2015, the sum of the value-added tax (including additional dues) as of January 30, 2015, 139,679,290 won was delinquent.

B. On May 2, 2016, the deceased on May 2, 2016, the deceased on the part of B, and on September 6, 2017, the registration of transfer of ownership (hereinafter “the registration of transfer of ownership”) was completed to the Defendant, who is the mother of B, due to the agreement on division of inherited property (hereinafter “instant partition agreement”) on May 2, 2016 regarding each real estate listed in the separate sheet (hereinafter “instant real estate”) as an inherited property listed in paragraph (1) of the attached list, and the real estate listed in paragraph (2) of the attached list, as indicated in paragraph (2) of the attached list.

C. As to the instant real estate No. 1, the registration of creation of a mortgage (hereinafter “registration of creation of a mortgage of this case”) was completed on September 6, 2017, the maximum debt amount of KRW 14 billion, the debtor, the defendant, and the association of the mortgagee D, which was the association.

B’s shares in inheritance are 2/9, and B is in excess of obligations as of May 2016 and the date of the closing of the instant argument.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 2, 3, 5, and 6 (including those with provisional numbers, and hereinafter the same shall apply) and the purport of the whole pleadings

2. Determination

A. 1) According to the above facts of recognition, the Plaintiff’s tax claim against B (hereinafter “instant claim”) is established.

shall be the preserved claim of the obligee's right of revocation.

The agreement on division of inherited property is to confirm the reversion of inherited property by either having all or part of the inherited property owned by each inheritor separately or having it performed as a new co-ownership relationship with respect to the inherited property which has been provisionally owned by co-inheritors upon commencement of inheritance, and therefore, it can be subject to the exercise of the right to revoke fraudulent act. As such, the agreement on division of inherited property by a debtor in excess of the debt is reached, and the result of division of property falls short of the extent equivalent to the debtor's share of inheritance.