2. The costs of lawsuit shall be borne by the Plaintiff.

A. The Plaintiff owned claim amounting to KRW 93,895,463 due to the cancellation of the contract and damages for delay pertaining to the refund due to the termination of the contract for the construction company Echina (hereinafter “ Echina Construction”).

B. The Plaintiff completed the registration of the establishment of a neighboring mortgage, which constitutes a maximum debt amount of 120,000,000 on October 10, 2012, with respect to the 4/10 portion owned by the 4/10 unit construction among the 210,00-dong 1603 (hereinafter “instant apartment”).

C. The Sungnam City seized the shares of the AP Construction among the apartment apartment of this case on the ground that the AP Construction failed to pay local taxes, and then requested the Defendant to sell the shares by proxy.

(hereinafter “instant public auction procedure”). D.

In the instant public sale procedure, the Plaintiff demanded the distribution of the proceeds from the sale on the basis of the above collateral security, and on July 14, 2015, the Sungnam Mayor requested the delivery of KRW 1,979,387,50 in the amount of delinquent local taxes in arrears, and on July 21, 2015, the head of the tax office having jurisdiction over the branch office requested the delivery of KRW 19,027,362,260 in the amount of delinquent local taxes

E. On July 29, 2015, the Defendant: (a) distributed KRW 172,30,000 for the sales price and KRW 54,720 for the shares in the AP construction among the instant apartment units; (b) KRW 172,354,720 for the sales price and KRW 54,720 for the deposit interest; (c) KRW 765,820 for the first priority disposition fee for arrears; (d) KRW 765,820 for the second priority disposition fee for arrears; and (e) KRW 62,968,061 for the second priority order and KRW 103,185,349 for the second priority order; and (e) drafted a distribution statement to the effect that there is no amount distributed to the Plaintiff

hereinafter referred to as "disposition of this case"

(f) The Plaintiff raised an objection to the said distribution statement on the distribution date of the above sale price. [The Plaintiff did not have any dispute over the grounds for recognition, each entry in Gap evidence Nos. 1 and 5, and the purport of the whole pleadings.

2. Determination on this safety defense

A. As a summary of the Defendant’s assertion, the Plaintiff directly appropriated the tax amount to be appropriated by the instant public sale procedure against the administrative agency that rendered the tax imposition disposition.