1. The plaintiff's claim is dismissed.

2. Litigation costs shall be borne by the plaintiff.

1. Basic facts

A. (1) On July 19, 201, the rehabilitation procedure based on the U.S. District Court Decision 2011 Ma12 was commenced on July 19, 201 with respect to the rehabilitation company Yong-Nam Fast Co., Ltd. (hereinafter “the rehabilitation company”).

(2) The Plaintiff was appointed as a custodian of the rehabilitation company in the above rehabilitation procedure.

(3) On May 17, 2012, the Ulsan District Court rendered the rehabilitation company approval order.

B. (1) During the period from January 7, 2013 to January 11, 2013, the head of the Dongsan District Tax Office under the Defendant’s control investigated the suspicion of omitting sales in the taxable period from July 1, 2011 to December 31, 2012, and confirmed the fact, such as omitting sales tickets.

(2) On March 2013, the head of the Ulsan District Tax Office calculated the omission amount in sales in 2011 as KRW 99,056,50, and treated it as a representative bonus and served a notice of change in the amount of income on the rehabilitation company.

(3) As the rehabilitation company did not pay the withholding tax based on the above change in income amount, the head of the Ulsan District Tax Office, around August 2013, notified the rehabilitation company of the correction of the tax amount of KRW 25,529,072 as earned income tax for the year 201.

(hereinafter referred to as the “instant correction notice”). C.

(1) On May 2, 2014, the head of the Ulsan District Tax Office attached a corporate free deposit account (Account No. 355-012-2313-13), which the rehabilitation company did not pay the withheld labor income tax based on the notice of correction of the instant case.

(2) On May 15, 2014, the head of the Ulsan District Tax Office collected part of the above attached deposit claims according to the procedure for disposition on default, and appropriated them to KRW 27,208,08,080 in total, including the wage and salary income tax and related additional charges based on the notice of correction of this case.

[Ground of recognition] Facts without dispute, Gap evidence 1, Eul evidence 2-1, 2, Eul evidence 1-3, 2-2.