1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

The plaintiff's assertion in the court of first instance is not significantly different from the argument in the court of first instance. However, considering the evidence submitted in the court of first instance, the fact-finding and judgment in the court of first instance are deemed legitimate.

Therefore, the court's explanation on this case is consistent with the reasoning of the judgment of the court of first instance except for the following modifications of some of the grounds of the judgment of the court of first instance. Thus, it is citing this as it is in accordance with the main sentence of Article 420 of the

Pursuant to the text of the first instance judgment, the first instance court’s first instance judgment, “The Debtor Rehabilitation and Bankruptcy Act” is deemed to be “the Debtor Rehabilitation and Bankruptcy Act (hereinafter “the Debtor Rehabilitation Act”), and the fifth and fourth instances “the Debtor Rehabilitation and Bankruptcy Act” is deemed to be “the Debtor Rehabilitation Act”, respectively.

(O) From the fifth to fourth half of the judgment of the first instance, "the administrative agency under Article 6 (2) of the Administrative Vicarious Execution Act has prior ownership of national tax next priority" shall be construed as "it can be collected in accordance with the example of the National Tax Collection Act under Article 6 (1) of the Administrative Vicarious Execution Act."

Pursuant to the fifth and seventh sentence of the judgment of the court of first instance, "the next priority of national tax under Article 6 (2) of the Administrative Vicarious Execution Act" shall be construed as "it can be collected in accordance with the example of the National Tax Collection Act under Article 6 (1) of the Administrative Vicarious Execution Act."

O The following matters shall be added after the 5th 9th eth son of the judgment of the first instance.

"The plaintiff asserts that, regardless of whether the insurer who subrogated for a tax claim exercises a tax claim against a delinquent taxpayer on behalf of the tax authority, the claim is recognized as a priority claim under the Debtor Rehabilitation Act regardless of whether the disposition for arrears was actually made (see Supreme Court Decision 2005Da32418, Feb. 26, 2009). The plaintiff asserts that, even if the vicarious execution was not actually executed, the claim that the plaintiff acquired against the defendant can constitute an "expenses for vicarious execution" claim that constitutes a estate claim.