(a) between C and D on March 17, 2016.

A. D is the spouse of C, and the Defendants are their children.

B. From November 15, 2011 to October 31, 2013, C engaged in a construction business with the trade name “G” in Geumcheon-gu, Geumcheon-gu, Seoul.

C. Around April 2016, the calendar tax secretary of the Plaintiff-affiliated C conducted a tax investigation with respect to G-related C, and found that C was omitted from 2012 to 2013, and around September 2016, C determined the total amount of KRW 379,414,600 as value-added tax for the period from February 2012 to February 2013, 2016.

However, since C did not pay global income tax and value-added tax imposed by the Plaintiff by the due date, the total amount of delinquent tax reaches KRW 481,856,010 as listed in Table 1 as of June 2, 2018.

C

D. C entered into a gift agreement with Defendant A on March 17, 2016 with regard to real estate listed in the separate sheet No. 1, and completed the registration of ownership transfer on the said real estate in the future of Defendant A on the same day. At the time, the registration of establishment of a neighboring mortgage was completed with regard to the said real estate at the time, which was KRW 19,50,000,000, and C was granted a loan of KRW 15,000 as security, and therefore, the said real estate had no real value as security on the date of the donation agreement.

E. In addition, on March 17, 2016, C entered into a gift agreement with D and Defendant B (hereinafter “instant gift agreement”) with respect to the real estate listed in the separate sheet 2 attached hereto (hereinafter “instant real estate”). On the same day, C completed the registration of ownership transfer with respect to 5/6 shares of the instant real estate and 1/6 shares of the instant real estate to D and Defendant B.

F. Meanwhile, D died on January 29, 2018, and Defendant A completed the entire registration of transfer of shares on June 18, 2018, which was based on inheritance by consultation and division, on January 29, 2016.

G. C at the time of the instant gift agreement, this case’s gift agreement