1. The real estate listed in the separate sheet No. 3/4 of the Defendant’s share in the real estate indicated in the separate sheet No. 2 between the Defendant and Nonparty B.

1. Facts of recognition;

A. B’s delinquency in paying capital gains tax amounting to KRW 136,294,530 for the year 2006, which was due date for payment on July 31, 2010, the Plaintiff has a tax claim amounting to KRW 136,294,530 against B.

B. B’s mother C (hereinafter “the deceased”) owned real estate listed in the separate sheet (hereinafter “instant real estate”) and died. On April 20, 2015, the inheritor, Defendant, D, E, and B (hereinafter “instant division agreement”) entered into an agreement on division of inherited property (hereinafter “instant division agreement”) with respect to the instant real estate on April 20, 2015, by inheritance of the shares of 3/4 and 1/4 of E, and the Defendant completed the registration of ownership transfer with respect to the shares of 3/4 of the instant real estate on April 28, 2015.

C. B did not have any property other than the instant real property at the time of the split-off consultation.

[Ground of recognition] Facts without dispute, entry of Gap evidence Nos. 1 through 4, purport of the whole pleadings

2. Determination

A. Determination on the cause of a claim 1) Division agreement of inherited property is a legal act in which the reversion of inherited property is finalized by having all or part of the inherited property provisionally owned by each inheritor or performed as a new co-inheritors with respect to the inherited property, and thus, it becomes subject to the exercise of the right to revoke a fraudulent act. Meanwhile, barring special circumstances, barring any special circumstance, the debtor's act of selling real property, which is only the property of his/her own, and changing in money or transferring it to another person without compensation, constitutes a fraudulent act against the creditor. Thus, even in cases where the debtor in excess of his/her obligation already renounced his/her right to share of inherited property upon consultation on division of inherited property, thereby reducing joint security against the creditor, in principle, constitutes a fraudulent act against the creditor (see Supreme Court Decision 2007Da29119, Jul. 26, 2007).