1. Revocation of the first instance judgment.

2. The Defendant’s transfer income tax amounting to KRW 91,100,360 for the Plaintiff on February 6, 2017.

1. The reasons why the court should explain this part of the disposition are the same as the entry of "1. Reasons for the disposition" recorded in the second-third of the judgment of the court of first instance. Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Whether the instant disposition is lawful

A. Each service alleged by the plaintiff by the defendant is invalid as follows.

Therefore, since the instant disposition was not legally delivered to the Plaintiff, it is null and void as it did not take effect.

1) The Defendant asserts to the effect that the delivery of this case was made as the Defendant’s public official issued a tax notice to the Plaintiff’s apartment security guards at the Plaintiff’s address on February 9, 2017. However, the delivery of this case’s security guards on February 9, 2017 is not lawful and effective, since the above security guards’ right to receive the registered mail, etc. is not recognized. 2) The Defendant’s public official’s refusal of delivery of this case’s custody did not constitute a lawful and effective delivery. The Defendant’s refusal of delivery to the above J’s address on February 9, 2017, which is the Plaintiff’s JJ’s domicile, but did not fall under the Plaintiff’s address, place of business or office, and did not fall under the Plaintiff’s lawful delivery of the notice. However, the Defendant did not constitute a lawful delivery of the Plaintiff’s remaining domicile at the time of February 9, 2017.

3. In cases of service by public notice under Article 11(1)3 of the Framework Act on National Taxes and Article 7-2(2) of the Enforcement Decree of the Framework Act on National Taxes, (1) existing service by public notice shall be served by taxpayers.