The costs of appeal are assessed against the Plaintiff.

1. Article 36 of the Framework Act on National Taxes and Article 101 of the Framework Act on Local Taxes declare “the principle of priority by seizure” that the taxes seized earlier are more than those requested for delivery of national taxes and national taxes, between national taxes and local taxes, and between national taxes and local taxes.

In the meantime, Article 37 of the Framework Act on National Taxes provides that when a property which has the security for tax payment is sold, national taxes, additional dues or disposition fees for arrears shall be collected in preference to other national taxes, additional dues or local taxes from the proceeds from sale, notwithstanding Article 36, and Article 102 of the Framework Act on Local Taxes shall be collected in preference to other local governments’ dues and national taxes, notwithstanding Article 101, if the property which has the security for tax payment is sold, the relevant local government shall be collected in preference to other local governments’ dues and national taxes. The provision provides that “national taxes with the security” and “national taxes without the security” shall be preferentially collected within the scope of the proceeds from the sale of the security for

The text and structure of these regulations, and “the principle of priority of secured taxes” can not proceed with the procedure of collection or disposition for arrears as a tax payer who has been provided security for tax payment, deferred the seizure of property by disposition for arrears, or deferred the sale of attached property. In certain cases, considering the circumstances where the seizure of attached property should also be cancelled, the purpose of securing the effectiveness of the security system is to collect the “security tax” in preference to other taxes within the scope of the proceeds from the sale of the security for tax payment. It constitutes an exception to “the principle of priority by seizure,” and Article 29 of the Framework Act on National Taxes includes land and buildings registered.