1. A donation contract concluded on January 11, 2016 between the defendant and the non-party B regarding the real estate stated in the separate sheet.

1. Basic facts

A. B, who was in office as the representative director of C, filed a return on the tax amount of KRW 5,704,941,172 as of August 11, 2017, and KRW 4,00,000 and KRW 13,500,000, which was paid by the said company, as of KRW 5,704,941,172 as of August 201, 2014, which was paid by the said company, and filed a return on the tax amount of KRW 2,612,30,00 after the deadline for global income tax for the year 2014,

B. On December 1, 2017, the head of the same tax office issued a correction and notification to B on December 1, 2017 that the global income tax of KRW 2,564,195,746 for the year 2014 should be paid by December 31, 2017. B did not pay the said global income tax, and as regards the said global income tax, the tax amount in arrears, including the additional dues, has reached KRW 2,948,825,010 as shown below [Attachment 1]:

[Attachment 1] Non-Party B’s amount of national taxes in arrears (as of December 1, 2018: the unit): the notified amount of tax due on the date of notification of the amount of national taxes in arrears (including additional dues) reverted to the original tax items, shall be determined on December 31, 2017, 2018.

B On January 11, 2016, the Defendant entered into a donation contract with the wife (hereinafter “instant donation contract”) with respect to the real estate listed in the separate sheet owned by him (hereinafter “the instant real estate”), and completed the registration of ownership transfer to the Defendant on the same day as indicated in the order.

B did not have any particular positive property except for the real estate of this case, the value of which is equivalent to KRW 53 million at the time of entering into the gift contract of this case and the shares equivalent to KRW 100 million.

E. Meanwhile, on October 13, 2005, B obtained a loan of KRW 16,00,000 from D with a collateral (the maximum debt amount of collateral 19,200,000,000) of the instant real estate, and around November 13, 2015, B repaid all the principal and interest of the loan.

[Ground of recognition] Facts without dispute, Gap 1-7 evidence, Eul 1-1 evidence (including paper numbers), the result of this court's order to submit financial transaction information to D Co., Ltd., and the purport of the whole pleadings

2. Determination

(a)the existence of the preserved claim;