The judgment below is reversed and the case is remanded to Seoul High Court.

The grounds of appeal are examined.

1. A third party, other than the other party of an administrative disposition, who is not the direct party of a legal claim regarding a legal interest, may file a revocation lawsuit in which the legal interest protected by the administrative disposition is infringed on by the law, and the legal interest here refers to the individual, direct and specific interest protected by the relevant administrative disposition and relevant Acts and subordinate statutes;

(2) The court below held that the plaintiff's claim for revocation of the distribution of shares of this case was a legal interest in filing an appeal against the sales price of shares of this case, since all creditors have not received the entire amount of their claim in distribution of the sales price of shares 7,767,470 shares of this case (hereinafter "the shares of this case") after finding facts as stated in the judgment of the court below based on the adopted evidence. Thus, the plaintiff's claim for revocation of the distribution does not dispute the distribution order among creditors in the situation where creditors have received the entire amount of their claim, and the sales price of shares of this case does not dispute only the distribution order among creditors in the situation where creditors have received the entire amount of their claim. The plaintiff is in a legally favorable position with regard to additional dues or prescription, since the plaintiff is in a position with regard to the distribution of shares of this case where the sales price of the shares of this case and the local

In light of the above legal principles, the above determination by the court below is just, and contrary to the allegations in the grounds of appeal, the court below did not err by misapprehending the legal principles on the legal interest in the

2. As to the assertion regarding the scope of the taxation claims that can be distributed

A. The latter part of Article 83(1) of the former National Tax Collection Act (amended by Act No. 10527, Apr. 4, 2011; hereinafter the same) is subject to distribution until the head of a tax office prepares a distribution statement.