1. The defendants' appeal is dismissed.

2. The costs of appeal are assessed against the Defendants.

Purport of claim and appeal

(b).

1. Basic facts

A. On July 9, 2007, the KUG notified C of the payment of capital gains tax of KRW 208,980,610 for the year 2007, and on August 14, 2016, the amount in arrears of capital gains tax of KRW 365,715,620 for the capital gains tax of KRW 365,715,620.

B. D The deceased on May 2, 2015 (hereinafter “the deceased”), and the heir had the Defendant B, C, E, and F, the spouse of the Defendant A, C, E, and F.

The inheritance shares of Defendant A are 3/11, and the remaining inheritors are 2/11, respectively.

C. On May 2, 2015, C renounced the inheritance share (2/11) in respect of each real estate listed in the separate sheet 1 and 2, which is the inherited property of the deceased, with respect to the deceased’s successors, including the Defendants, and each real estate listed in the separate sheet 1 and 2, and Defendant A made an agreement on division of inherited property (hereinafter “instant agreement on division of inherited property”) with respect to each real estate listed in the separate sheet 1 and 2, which is the inherited property of the deceased.

Accordingly, Defendant A completed the registration of ownership transfer on September 23, 2015, and Defendant B completed the registration of ownership transfer on December 1, 2015 as to the real estate listed in the separate sheet No. 1, and on December 1, 2015, based on each of the instant inherited property division consultation. D.

C At the time of the consultation on division of the inherited property of this case, there was no particular property other than the inherited property of the deceased.

[Reasons for Recognition] Facts without dispute, entry in Gap evidence 1 through 4, and 6 (including virtual numbers, unless otherwise specified; hereinafter the same shall apply), the purport of whole pleadings

2. Determination

A. The agreement on the division of the inherited property established by a fraudulent act is to confirm the reversion of the inherited property by either having all or part of the inherited property, which was provisionally owned by the co-inheritors upon commencement of inheritance, as the sole ownership of each inheritor, or by performing as a new co-ownership relationship, and therefore, it is a juristic act the object of which is property right, and thus, can be the exercise of the right

On the other hand, the debtor is the only property.