1. The judgment of the court of first instance is modified as follows.

The amount of KRW 847,00,000, which was concluded on August 13, 2012 between Defendant and B is KRW 847,00.

1. Basic facts

A. B’s sale of the instant real estate 1) B is the “instant real estate” of Gangnam-gu Seoul Metropolitan Government E Land and Building on August 9, 2012 (hereinafter referred to as “instant real estate”) to C and D on August 9, 2012.

B) In selling KRW 8.25 billion, the Plaintiff agreed to sell the said real estate at KRW 8.25 billion, and that the buyer succeeds to a total of KRW 3.38 billion, including the secured debt of the right to collateral security and the secured debt of the lease deposit, which was established in the name of the new bank, a new bank for the said real estate (hereinafter “instant sales contract”). B agreed to receive only the difference of KRW 4.87 billion as the remainder (hereinafter “instant sales contract”).

(2) On August 13, 2012, B: (a) completed the registration of ownership transfer on the said real estate to the said purchaser; (b) cancelled other collateral security and seizure registration established on the said real estate; and (c) received the remainder of KRW 4.87 billion from the said purchaser on the same day.

B. On August 13, 2012, the instant gift B against the Defendant: (a) donated KRW 847 billion to the Defendant, who is one’s own wife on August 13, 2012, and (b) immediately transferred the said remaining amount from the buyer, the Defendant transferred the said remaining amount to the Defendant’s account (hereinafter “instant gift”).

C. The Plaintiff’s taxation B made a preliminary return on the tax base of capital gains following the sale of the said real estate, but did not pay capital gains tax of KRW 1,663,075,809, which was determined as of January 10, 2013 as KRW 1,683,282,179 (the amount obtained by adding additional tax to the original determined tax amount of KRW 20,206,370) and is still delinquent until now.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1-3, 7, and 10 (including paper numbers; hereinafter the same shall apply), Gap witness B's testimony, and the purport of the whole pleadings

2. Determination as to the cause of action

A. According to the facts acknowledged prior to the existence of preserved claims, the Plaintiff’s taxation claim of this case shall be reported as tax base B after the donation of this case and the tax authority’s additional tax.