A. B’s liability to pay capital gains tax 1) B is as follows: C Co., Ltd. (hereinafter “C”) on April 25, 2013.

(2) the title of the real estate listed in the separate sheet (hereinafter referred to as “instant real estate”).

(2) On July 31, 2013, B entered into a transfer contract that transfers transfer proceeds of KRW 2,250,000,000, and completed the transfer registration of ownership on May 30, 2013, B made a preliminary return of transfer income tax on the instant real estate to the director of the Busan District Tax Office affiliated with the Plaintiff on July 31, 2013. The director of the Incheon District Tax Office notified B of KRW 487,050,410 of transfer income tax as the due date on October 31, 2013, who did not pay taxes after filing a return of transfer income tax.

However, B did not pay capital gains tax, and capital gains tax on B including additional dues of 67,212,910 won as of August 26, 2014 is 554,263,320 won.

B. B’s assignment 1) Claim B refers to a claim with the remaining amount of KRW 1 billion out of KRW 2,250,000,000 of the transfer proceeds of the instant real estate on May 28, 2013 (hereinafter “instant claim”).

B) On May 28, 2013, in order to secure the remainder of KRW 1 billion against the Defendant, C and the Defendant: (a) prepared a written statement of performance with respect to the aggregate building of this case with respect to land and buildings, such as the right to collateral security, the maximum debt amount of KRW 300 million, and the right to collateral security; (b) issued a promissory note with respect to the issuer C and C’s representative director E, the due date of payment of KRW 1 billion, March 30, 2014, against the Defendant; and (c) written an authentic deed with respect to the instant real estate to B on May 30, 2013; and (c) paid KRW 1,250,000,000 among the transfer proceeds of real estate of this case to the Defendant; and (d) the remainder to be paid by C to the Defendant by August 26, 2014.

C. B’s financial status was in excess of the debt at the time of the assignment of the instant claim on May 28, 2013.

[Ground of recognition] Facts without dispute, entry of Gap evidence 1 to 5, purport of the whole pleadings

2. Revocation of a fraudulent act;