1. On January 28, 2016 between the defendant and the non-party B, 1/9 of the real estate stated in the attached Table concluded on January 28, 2016.

1. Facts of recognition;

A. B, as a taxpayer or secondary tax obligor, did not pay national taxes of KRW 440,712,530 in total to the Plaintiff as follows (hereinafter “instant tax claim”).

B. C died on January 28, 2016, and upon the death of the deceased, the Defendant, the spouse of the deceased, and B, D, and E inherited the deceased’s property.

C. The real estate indicated in the separate sheet (hereinafter “instant real estate”) was owned by C. The Defendant, B, D, and E, retroactively from the date of commencing an inheritance, entered into an agreement on division of the inherited property to be inherited solely by the Defendant (hereinafter “instant agreement on division”).

Accordingly, on March 28, 2016, the registration of ownership transfer of the instant real estate was completed in the Defendant’s future.

At the time of the agreement division contract of this case, B was in excess of the obligation.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 4, Eul evidence No. 7, the purport of the whole pleadings

2. Assertion and determination

A. As a matter of principle, a creditor’s fraudulent act constitutes a fraudulent act against a general creditor even if the joint security against the general creditor has decreased due to the waiver of his/her right to share of inherited property upon the split-off agreement of the inherited property by the debtor with respect to the secured claim

(See Supreme Court Decision 2007Da29119 Decided July 26, 2007, etc.). According to the above facts of recognition, the Plaintiff’s instant tax claim against B with respect to preserved bonds, and the Plaintiff’s agreement for the instant division to the effect that he/she owns his/her inheritance shares (2/9) regarding the instant real estate in excess of the obligor B’s debt belongs to the Defendant constitutes a fraudulent act against the Plaintiff, a creditor, barring special circumstances, and the Defendant’s bad faith, a beneficiary, is presumed.

B. The plaintiff asserts that the scope of revocation of the fraudulent act is one party, and the real estate in this case is the deceased C's inherited property, and among them, is the 2/9.