1. The Defendant’s KRW 394,500,000 and annual interest thereon from April 2, 2016 to July 21, 2017 to the Plaintiff.

1. Basic facts

A. The Plaintiff is a person who holds a national tax claim of KRW 863,355,820 against Non-Party B Co., Ltd. (hereinafter “B”).

B. B’s transfer of shares to the Defendant Company B (hereinafter “instant transfer”) on April 20, 2012, the Defendant Company: (a) transferred the right to claim the return of the shares issued by Nonparty C Co., Ltd. (hereinafter “instant transfer”) to the Defendant Company in KRW 1.5 billion; (b) the right to claim the return of the shares 2,545,49 shares that

(2) The Defendant Company issued three promissory notes with the amount of KRW 500 million on the same day, and the Defendant Company received KRW 1.5 billion from the instant transfer price to the Defendant Company.

B and the Defendant Company agreed to keep three copies of the Promissory Notes on the same day in the law firm (with limited liability).

3) On January 21, 2013 and December 4, 2013, B received a total of KRW 1 billion from the Defendant Company. (c) The director of the Songpa District Tax Office affiliated with the Plaintiff attached the Plaintiff’s national tax claim claim against B on October 28, 2015 and the unpaid claim against B (hereinafter “instant claim”) among the transfer proceeds of this case owned by B against the Defendant Company based on KRW 842,797,150, and the notice of attachment of the claim reaches the Defendant Company on November 2, 2015.

2) On November 2, 2015, by sending a written request for collection of seized claims, stating that the accounts payable to Defendant Company B and the Defendant Company B are paid, the director of the tax office sent the written request to the Defendant on November 2, 2015.

2. Determination

A. According to the facts of recognition as to the cause of the claim, B holds a claim of KRW 500 million against the amount payable out of the transfer price of this case with the Defendant Company, and pursuant to Article 41(2) of the National Tax Collection Act, when the chief of a tax office has notified a monetary claim upon seizure, he/she may subrogate the obligee, who is the delinquent, to the extent of delinquent amount.

(c).