A. B, on February 1, 2016, sold land and buildings owned by it to E (hereinafter “instant real estate”) for each of the land and buildings owned by it (hereinafter “instant real estate transaction”), and sold KRW 569,00,000, out of the remainder of KRW 570,000,000 to E (hereinafter “instant real estate transaction”), to the Defendant, who was the check, as the check, and the Defendant deposited this into his account.

(hereinafter “instant donation contract”). (b)

On the other hand, B did not file a preliminary return of capital gains tax despite having obtained gains from the sale and purchase of the instant real estate, and the Defendant filed a return after November 3, 2016, but did not pay capital gains tax calculated. On March 3, 2017, B submitted an application for reduction or exemption of additional tax on the ground that B failed to file a return or payment of capital gains tax due to a traffic accident that is a taxpayer on March 3,

C. The head of the Gwangju District Tax Office under the Plaintiff-affiliated Tax Office determined and notified the final payment deadline of KRW 107,788,745, except for the penalty tax for filing a return and an unfaithful payment, as of May 15, 2017, but B did not pay the final payment deadline.

As of April 2018, B's delinquent national taxes amounted to KRW 123,957,00 (including additional dues of KRW 16,188,255).

[Ground of recognition] Facts without dispute, Gap evidence 1 to Gap evidence 10, Gap evidence 11-1 and 2, the purport of the whole pleadings

2. Determination

A. Although the existence of preserved claims is after the gift contract of this case that the Plaintiff imposed capital gains tax on the sale of the real estate of this case, according to the above recognition facts, the basic legal relationship on which the Plaintiff imposes capital gains tax was established due to the sale and purchase of the real estate of this case of this case, and there was a high probability that the Plaintiff would impose capital gains tax within the nearest time. In fact, the Plaintiff’s claim for taxation of this case was established by notification of capital gains tax around April 2017, and thus, the Plaintiff’s claim of this case

(b) Evidence A No. 7, No. 9, and A.