The costs of appeal are assessed against the Plaintiff.

1. As to the grounds of appeal Nos. 1, 2, and 3, the lower court: (a) seized the Plaintiff’s loan claims against the Defendant (10,458,319,46 won as stated in the Defendant’s audit report) to collect capital gains tax on the Intervenor A; and (b) claimed that the Defendant is obligated to pay the amount equivalent to the above loan claims to the Plaintiff; (c) thus, the obligee is obliged to prove the existence of the claim subject to seizure in the lawsuit for collection based on the claim seizure and collection order; (d) A and F Co., Ltd. (hereinafter “F”) which led the division accounting of the Group C to the same affiliated company by creating a false account, i.e., “the short-term loan account in the same affiliated company” with the Defendant, and i., including the Defendant’s funds distributed to other affiliated companies, and then, appropriated the same as the principal loan in the short-term loan in the Defendant’s account book, or paid the same as the Defendant’s personal funds to the Defendant’s affiliated company for more than 100 billion won.