1. The attachment of claims in attached Form 2 regarding the portion exceeding 64,646,740 won among the instant lawsuits.

1. Details of the disposition;

A. From August 11, 1997 to February 28, 2001, the Plaintiff engaged in construction machinery rental business under the trade name “C” in Yeongdeungpo-gu Seoul Metropolitan Government. In relation to the above business, each value-added tax listed in attached Table 1 (hereinafter “each value-added tax of this case”) was delinquent.

B. Upon the Plaintiff’s commencement of the voluntary auction procedure for real estate E (hereinafter “instant auction procedure”) with respect to the land size of 218 square meters in Gyeyang-gu, Seoyang-gu, Sungyang-gu, the mortgagee, the mortgagee of the right to collateral security, on August 28, 2018, the Defendant seized the claim indicated in attached Table 2 (hereinafter “instant attachment disposition”).

C. On November 28, 2018, the Plaintiff filed an appeal seeking the revocation of the instant attachment disposition with the Tax Tribunal, but was dismissed on April 2, 2019.

[Ground of recognition] Facts without dispute, Gap evidence 1, 2, Eul evidence 4 and 6, the purport of the whole pleadings

2. Attached Form 3 of the relevant Acts and subordinate statutes;

3. We examine ex officio determination on the part of the instant lawsuit which exceeds 64,646,740 won in arrears as to the revocation request for the attachment disposition of this case.

The benefit of a lawsuit to dispute an administrative disposition shall be determined in consideration of individual and specific circumstances.

Even if a lawsuit seeking nullification or revocation of an administrative disposition is lawful at the time of filing a lawsuit, if the disposition agency ex officio revokes an administrative disposition which is the object of dispute during the proceeding of the lawsuit, the disposition loses its validity and does not exist any longer. Thus, an appeal suit against the disposition that does not exist should, in principle, be deemed unlawful on the grounds that the interest of the

(see, e.g., Supreme Court Decision 2004Du5317, Sept. 28, 2006). However, despite the ex officio revocation of a disposition agency, a complete restitution is not made, and thus, it becomes invalid or cancelled.