1. On March 24, 2017, the sales contract for the sales right entered in the separate sheet between the defendant and the non-party B was concluded.

1. Facts of recognition;

A. Nonparty B confirmed the omission in filing a return on cash sales from February 27, 2017 to March 18, 2017 from the date of the personal integrated investigation conducted by the Director of the Statistics Korea as the representative of “F” to March 18, 2017 to the date of filing a return, and the Director of the Statistics Korea imposed on B the amount of value-added tax of KRW 210,018,350, global income tax of KRW 358,879,210 (hereinafter “instant tax claim”) on May 10, 2017 as the due date for payment.

B. On March 24, 2017, B entered into a contract with the Defendant to sell in KRW 542,400,000 the sales rights listed in the separate sheet (hereinafter “instant sales rights”) (hereinafter “instant sales contract”) with the Defendant, and the same year.

4. 5. The trustee and the developer Co., Ltd., the trustor and the implementer Co., Ltd. and the contractor Co., Ltd. reported the succession of rights and duties to change the purchaser’s name to the defendant.

C. At the time of the instant sales contract, B did not have any particular property other than the instant sales right, and the small property was in excess of the positive property.

[Reasons for Recognition] Unsatisfy, entry of Gap evidence 1 to 10, the purport of the whole pleadings

2. The establishment of a fraudulent act;

A. Although it is required that a claim protected by the obligee’s right of revocation was, in principle, arisen prior to the commission of an act that can be deemed a fraudulent act. However, at the time of a fraudulent act, there is a high probability as to the existence of a legal relationship which is the basis of the establishment of a claim, and the claim is established in the near future by such legal relationship, and in the near future, where a claim has been created due to its realization in the near future, such claim may also become a preserved claim of the obligee’s right

(see, e.g., Supreme Court Decision 2011Da76426, Feb. 23, 2012). Accordingly, the instant tax claim was not created as of March 24, 2017, which was the date of the instant sales contract.

Even in this case.