A sales contract concluded on April 21, 2014 with respect to each real estate listed in the separate sheet between the defendant and B shall be 87,85.

A. On May 7, 2014, the head of the tax office of the Jeonju under the Plaintiff’s control issued a notice to pay KRW 122,165,630, value-added tax totaling KRW 70,843,970, and KRW 193,09,600, as of August 22, 2016, the Plaintiff’s global income tax and value-added tax are KRW 193,09,600, and KRW 66,07,790, total amount of KRW 259,017,390, as of May 31, 2014.

B. Registration of ownership transfer under the name of the defendant as to the instant real estate 1) The defendant on April 21, 2014 each of the real estate listed in the separate sheet from B (hereinafter “instant real estate”).

(2) At the time of April 21, 2014, the establishment registration of the instant real estate was completed on April 21, 2014, with the Jeonju District Court Decision No. 50814, Apr. 21, 2014, with respect to the instant real estate as KRW 100 million. The establishment registration was completed on April 21, 2014, with respect to the instant real estate, at the time of Geumma Agricultural Cooperative’s establishment registration was completed prior to the maximum debt amount of KRW 72 million under the name of Geumma Agricultural Cooperative. The Defendant repaid to Geumma Agricultural Cooperative the said collateral debt amount of KRW 60 million and revoked the said establishment registration on August 6, 2015.

C. At the time of the sales contract between the Defendant and B, B had no active property other than the instant real property of KRW 147,885,000 at the market price, and the land price of KRW 13 million at the following periods: (a) while the instant property was a passive property, there was a debt exceeding the amount of KRW 193,009,60 with respect to the Plaintiff’s tax liability of KRW 193,009,60 with respect to the instant property, and KRW 60,000 with respect to the gold Farming Cooperative established on the instant real property.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 4, 5, 8, 9, Gap evidence No. 2-1, 2, and Gap evidence No. 6-1, the witness Eul's testimony, and the purport of the whole pleadings

2. Determination on this safety defense

A. The Defendant’s assertion asserts that B sold the instant real estate to the Defendant was a fraudulent act and its revocation and restitution.