A. On November 1, 2016, the head of the competent tax office of the Plaintiff-affiliated tax office added KRW 171,428,448 to the global income tax on B, and KRW 26,56,127 to the amount corresponding to the year 2006, ③ KRW 113,068 to the amount corresponding to the year 209, and KRW 198,107,643 to the amount corresponding to the global income tax on B.

B. On April 17, 2014, B completed the registration of ownership transfer on April 16, 2014 with respect to each real estate listed in the separate sheet (hereinafter “each of the instant real estate”) to the Defendant on April 17, 2014.

C. At the time of the above sale, B had active property equivalent to KRW 118,904,565 in total, including each of the instant real property, and there was a small property equivalent to KRW 320,037,843 in total, including the Plaintiff’s tax claims, etc.

[Reasons for Recognition] Facts without dispute, Gap 1 through 8 (including the number of each branch; hereinafter the same shall apply), the purport of the whole pleadings

2. The assertion and judgment

A. Whether a preserved claim is established or not, the Plaintiff’s global income tax claim on B, 2005 to 2009, which belonged to the preserved claim, has already been established before the fraudulent act, and thus, may be the preserved claim of the obligee’s right of revocation.

In addition, the addition or exchange of the claim that the creditor intends to preserve while claiming the revocation of the fraudulent act is merely a change in the argument about the method of attack that makes the revocation of the fraudulent act reasonable, not a change in the subject matter of the lawsuit or the claim itself.

B. (See Supreme Court Decision 2001Da13532 delivered on May 27, 2003).

The act of selling the real estate of this case to the defendant under excess of debt B is presumed to have caused the result of reducing the obligees' joint collateral, and it is presumed that the defendant's bad faith as a beneficiary is presumed to have been presumed to have been intentional to B.

C. The defendant's assertion that the defendant did not have intention to harm the B and the defendant, but there is no evidence to acknowledge it.