On February 26, 2016, the share of each real estate listed in the separate sheet 1 through 3 between the defendant and the non-party B.

A. B was delinquent in national taxes of KRW 59,85,90 (value-added tax and global income tax), including the additional dues, as of January 22, 2018, as shown in Table 1 below:

(B) B B B B B B B B B B B of the above national tax claim, excluding additional dues.

B. B, from July 16, 2015, each of the real estate shares listed in the separate sheet No. 1 through No. 5 (hereinafter collectively referred to as “share of each of the instant real estate,” and the real estate shares listed in the separate sheet are inherited and completed the registration of transfer on February 4, 2016.

C. B signed a pre-sale agreement with the Defendant, who is the spouse of the same birth D, and ① on February 26, 2016, with respect to each of the instant real estate shares (hereinafter “instant pre-sale agreement”) and ordered on February 29, 2016 to the Defendant on February 1, 2016.

paragraphs 2 and 2-b

The provisional registration of each claim for transfer of share stated in paragraph (1) (hereinafter “the provisional registration of this case”) was completed, and ② on February 26, 2016, the sales contract was concluded with the limit of the share of real estate 1 to 3 real estate on February 26, 2016 (hereinafter “the sales contract of this case”) and the order 1-B to the Defendant on January 2, 2018.

The registration of transfer of each share in the subsection (hereinafter referred to as the "registration of transfer of the share in this case") was completed. D.

At the time of entering into the instant sales promise and sales contract, B held the share of each of the instant real estate in an amount equivalent to KRW 200,264,344 as active property, while holding the share of each of the instant real estate in excess of obligations, such as bearing the instant tax liability equivalent to KRW 322,448,90 in total as passive property.

[Ground of recognition] The fact that there has been no dispute, each entry of Gap's 1 through 7 (including each number; hereinafter the same shall apply), the result of a request for market price appraisal of appraiser E by this court, the purport of the whole pleadings

2. Determination

A. According to the fact that the existence of the preserved claim 1 exists and the establishment of the preserved claim is recognized, the Plaintiff has made the instant taxation claim against B prior to the conclusion of the instant trade reservation and the sales contract.