A. The parties 1) B are Jongno-gu Seoul Jongno-gu Seoul Metropolitan Government 99.2 square meters and above ground buildings (hereinafter “instant real estate”).

(2) The Plaintiff has a transfer income tax claim of KRW 562,519,870 as of November 15, 2017 against B.

B. 1) The Defendant’s land and the 4th floor accommodation building on the ground owned by the Defendant (hereinafter “D real estate”) in Ansan-si.

(E) as to Company E (hereinafter “E”).

(2) The lower court determined that the said right to collateral security was to be set up against the Defendant and the maximum debt amount of KRW 440 million; and that the said right to collateral security was to be set up as a collateral; KRW 40 million on June 3, 201; KRW 200 million on December 12, 201; KRW 15 million on December 15, 201; and KRW 360 million on April 6, 2012, KRW 360,000,000 (hereinafter referred to as “first loan”).

(2) Meanwhile, on September 13, 2012, B established the right to collateral security of KRW 650 million with respect to the instant real estate to F Co., Ltd. (hereinafter “F”), and was loaned KRW 500 million with respect to the said real estate (hereinafter “second loan”) on the same day.

C. B’s transfer of real estate and repayment of loans 1) B entered into a sales contract with G and H on November 14, 2014, selling the instant real estate in the amount of KRW 1.75 billion in the price. 2) B repaid loans on December 2, 2014, and on December 3, 2014.

2. The registration of the establishment of a neighboring real estate in the name of F as stated in paragraph 2 was cancelled, and the registration of the establishment of a neighboring real estate in the name of G and H was completed on December 30, 2014.

On December 2, 2014, the notice of attachment and delivery of the Plaintiff’s claim, the head of the final tax office, based on the Plaintiff’s notice of attachment and delivery, deemed that B repaid the Defendant’s second loan obligation to F and acquired the Defendant’s claim for reimbursement against the Defendant. On August 21, 2017, “in addition to the amount equivalent to national tax delinquency among the above claim for reimbursement, including the increased additional dues and disposition fee for arrears added in the future.”

On August 31, 2017, the chief of the final tax office is the defendant.