1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. Basic facts

A. On March 2, 2013, the director of the Ulsan District Tax Office under the Plaintiff’s control of the Plaintiff’s global income tax claim on B included KRW 198,039,031 of the business year (i.e., January 1, 201 through December 31, 2011) of C Co., Ltd. (hereinafter “C”) in the calculation of the corporate tax base; and (ii) included the omitted amount in the calculation of gross income in the calculation of gross income; and (iii) deemed that the said included amount included in gross income was reverted to the representative director B of the said corporation as at the time of the occurrence of the Plaintiff’s global income tax claim on the Plaintiff’s global income tax claim; and (iv) notified B of the payment of the relevant comprehensive income tax by sending the notice of change in the amount of income as to the disposition of the recognition of the instant case to the said corporation.

B The head of Dongsan District Tax Office, the Plaintiff’s head of the Dongsan District Tax Office having jurisdiction over the domicile of B, on June 2014, imposed global income tax for the taxable year 201 (hereinafter “instant tax claim”) of KRW 59,374,040 (payment deadline June 30, 2014) on B (hereinafter “instant tax claim”).

B. The gift B of the instant real estate entered into a contract with the Defendant, the wife, on June 24, 2014 (hereinafter “instant gift contract”); on the same day, the registration of ownership transfer was completed with the Busan District Court Branch Registry No. 51567 on the grounds of the contract.

C. B’s asset condition B was in excess of the obligation at the time of entering into the instant gift agreement, and there was no particular property other than the instant real estate.

On June 24, 2014, the Defendant entered into a mortgage establishment agreement with the Central Saemaul Depository of the mortgagee, the debtor, the maximum debt amount of 7,200,000 won with respect to the instant real estate on June 24, 2014, and on the same day, the registration of the establishment of the neighboring real estate was received by the Ulsan District Court, No. 51568.