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

The plaintiff is a company established on July 18, 2001 for the purpose of construction business, etc.

B kept 10,00 shares of the Plaintiff in the register of shareholders at the time of July 24, 2017 (8.19% of shares).

On July 24, 2017, the Defendant seized the Plaintiff’s 10,000 shares and the entire rights to the shares (the amount up to the delinquent amount among all the shareholders’ rights, such as the right to receive various dividends and the exercise of voting rights) (hereinafter “instant attachment disposition”), and notified the Plaintiff of the attachment of the claim on the same day.

[Grounds for recognition] The defendant asserts that the lawsuit of this case is unlawful since the lawsuit of this case was filed without going through the procedure of prior trial, such as a request for examination or a request for trial, under the Framework Act on National Taxes.

It shall be as shown in the attached Form of the relevant statutes.

Judgment

According to Articles 56(2), 61(1) and 68(1) of the Framework Act on National Taxes, where an administrative litigation is instituted against a disposition under the Framework Act on National Taxes or other tax-related Acts, a request for examination or adjudgment, etc. prescribed by the Framework Act on National Taxes, shall undergo such procedures, and a request for examination or adjudgment shall be filed within 90 days from the date the relevant disposition is known (where a notice

Meanwhile, Article 2 subparag. 2 of the Framework Act on National Taxes stipulates the National Tax Collection Act as one of the tax-related Acts, and Article 24(1) and Article 41 of the National Tax Collection Act provides for the seizure of claims as a procedure for the disposition on default. As such, the instant disposition on default under the National Tax Collection Act, which is a disposition on default, shall undergo a prior trial procedure under Article 56(2)

As to the attachment of the Plaintiff’s shares owned by the Defendant on July 24, 2017, the Plaintiff filed the instant lawsuit on February 12, 2019.