1. The plaintiff's appeal and the conjunctive claim added by this court are all dismissed.

2. After an appeal is filed.

1. Basic facts

A. On January 21, 2013, the director of the Seocho District Tax Office attached the Contact Membership Rights (27446) and the deposit refund claim (hereinafter “the instant deposit refund claim”) held by the said company against the large leisure industry, and around that time, the notice of attachment reached the large-scale leisure industry in charge of the general real estate holding tax in 2012, including KRW 3,804,191,80.

B. On October 22, 2014, the company was declared bankrupt by Seoul Central District Court No. 2014Hahap158.

The Plaintiff paid 29,812,060 won as substitute payment to its employees who were declared bankrupt, and requested the head of the Seocho District Tax Office to distribute the claim to return the deposit of this case to recover the substitute payment on March 24, 2015.

C. On July 8, 2015, the director of the Seocho District Tax Office collected the instant claim for refund of the deposit from the Daegu Leisure Industry, and appropriated the collection amount of KRW 19,400,000 (hereinafter “the collection amount in this case”) to the total amount of the national tax in arrears of the Pakistan.

[Ground of recognition] Unsatisfy, Gap evidence 1, 2, 4 (if there is a tentative number, including branch numbers; hereinafter the same shall apply), Eul evidence 1, the purport of the whole pleadings

2. Judgment as to the main claim

(a) A summary of the party's assertion (1) The plaintiff: Article 8 (2) of the Wage Claim Guarantee Act, and Article 35 (1) 5 of the Framework Act on National Taxes, Article 35 (1) 5 of the Framework Act on National Taxes shall be collected in preference to other public charges and other claims;

Provided, That the same shall not apply to any of the following public charges or other claims:

5. Where national taxes or the additional dues are collected from sale or collection of the employer's property, the wages, retirement allowances, accident compensation, or the amount paid preferentially to the national taxes and additional dues under Article 38 of the Labor Standards Act or Article 12 of the Guarantee of Workers' Retirement Benefits Act.