1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Basic facts

A. On February 24, 2017, the Defendant entered into a sales contract with B (hereinafter referred to as “B”) on the “Building D” (hereinafter referred to as the “instant building”) of the Yeongdeungpo-gu, Yeongdeungpo-gu, Seoul (hereinafter referred to as “instant sales contract”) and completed the registration of ownership transfer on March 13, 2017.

B. On June 15, 2018, in order to collect the total amount of delinquent local taxes, such as corporate tax, value-added tax, and wage and salary income tax, in arrears, KRW 5,191,493,690, the Plaintiff seized the outstanding amount of claims against the Defendant, and sent the notice of seizure of claims to the Defendant (hereinafter “Notice of seizure of claims”), and the above notice was served on the Defendant on June 20, 2018.

C. On February 21, 2019, the Plaintiff sent a notice to the Defendant demanding collection of KRW 529,070,420 of the amount of seized claims, and the said notice was served on the Defendant on February 25, 2019.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 2, 5, 7, 8, 9, 10, and the purport of the whole pleadings

2. The parties' assertion

A. The Defendant is obligated to pay the sales price to the national bank account in B as specified in the sales contract form. Since there is no balance payment other than the down payment (10%) to the above account, the Defendant is obligated to pay the remainder of 529,070,420 won to B. The Defendant is obligated to pay the said price to the Plaintiff according to the notice of the seizure of the claim.

B. The Defendant agreed that the sales price of the instant building was fully paid by concluding a loan agreement and a written agreement with Defendant B and implementing the content of the agreement. As such, there is no outstanding amount due for the Defendant’s sales of the instant building at the time of notifying the seizure of the instant claim.

3. Determination

A. In a case where a claim is seized by the head of a tax office in accordance with the procedure for the disposition on default under the National Tax Collection Act, the obligor of the seized claim cannot repay the obligation to the obligee. Meanwhile, the head of a tax office is in accordance with Article 41(2) of