A. On July 19, 2012, the Mutual Association concluded a monetary loan agreement with Non-Party C Co., Ltd. (hereinafter collectively referred to as “Non-Party D”) on July 20, 2012, and completed the registration of establishment of collateral security (hereinafter referred to as “the instant collateral security agreement”) with respect to the land of four parcels of land and its ground building and machinery (hereinafter referred to as “the instant secured object”) other than the land for land E in Youngcheon-si, the ownership of the Non-Party Company as the secured claim on July 20, 2012, using the maximum debt amount as KRW 1,638,000,000, Daegu District Court received by the registration office of Youngcheon-gu District Court (hereinafter referred to as “the instant secured property”).

B. Meanwhile, as the non-party company failed to pay national taxes, such as value-added tax, on May 21, 2013, the real estate of this case was seized pursuant to Article 24(1) of the National Tax Collection Act (amended by Act No. 11845, Aug. 29, 2013). The Youngcheon City seized the real estate of this case on July 3, 2013 pursuant to Article 91 of the Framework Act on Local Taxes (amended by Act No. 12047, Aug. 13, 2013).

C. On September 7, 2016, a cooperative filed an application for voluntary auction with the Daegu District Court FF to enforce its right to collateral security on the instant real estate and the said court decided to commence auction G on April 23, 2014.

(hereinafter “instant auction procedure”). D.

On December 12, 2016, when the instant auction procedure was in progress, the Mutual Association transferred its right to collateral security to the Plaintiff with respect to the non-party company, and completed additional registration on December 13, 2016. The Plaintiff reported the succession of right in the instant auction procedure.

E. In the instant auction procedure, on November 24, 2017, the director of the tax office of the Defendant-affiliated racing claimed the delivery of KRW 149,966,340, such as acquisition tax of the non-party company, to the amount of delinquent national taxes. On February 21, 2018, the Youngcheon City filed a claim for delivery of KRW 141,35,730, the amount of delinquent local taxes of the non-party company.

F. The instant case.