1. It was concluded on January 20, 2013 with respect to the share of 2/13 out of the real estate listed in the separate sheet between the Defendant and B.

1. Facts of recognition;

A. B did not file a voluntary return and pay the global income tax for the year 2010. Accordingly, the Plaintiff imposed a global income tax for the year 2010 on December 1, 2015 (i.e., the principal tax of KRW 146,601,860 plus KRW 16,712,590). As of February 4, 2017, the assessment of global income tax for the year 2010 is imposed on B (hereinafter “instant tax claim”).

On November 14, 2012, B’s father C died on November 14, 2012, co-inheritors, including the deceased’s wife, the deceased’s wife, and B (the 2/13 inheritance portion), entered into an agreement on the division of inherited property (hereinafter “instant agreement on the division of inherited property”) on January 20, 2013, with the content that the real estate listed in the attached list shall be owned solely by the Defendant.

C. At the time of the consultation on the division of the instant inherited property, the real estate No. 8 of Yongsan-gu Seoul Metropolitan Government (hereinafter “D real estate”) was located on the instant real estate with the active property of B, but the market value was KRW 530,000,000 as of February 19, 2013. At the time of the consultation on the division of the instant inherited property, the amount of the collateral security obligation of AviIk Capital Co., Ltd. established on the instant real estate was equivalent to KRW 464,00,000.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 6, Eul evidence No. 1, the purport of the whole pleadings

2. The Defendant filed a lawsuit seeking revocation of the instant fraudulent act after the lapse of one year, which is the exclusion period of the obligee’s right of revocation, even though the Plaintiff knew at the time of the said taxation or that there was an agreement on the division of the inherited property of this case at the time of the said taxation, and thus, the instant lawsuit is unlawful. Accordingly, the instant lawsuit is deemed unlawful.

In the exercise of the creditor's right of revocation, the date when the creditor, which is the starting point of the exclusion period, becomes aware of the cause of the revocation means the date when the debtor becomes aware of the fact that he had committed a fraudulent act while being aware that it would prejudice

This is not sufficient to say that the debtor simply conducted the act of disposal of the property, and it is concrete.