The defendant's appeal is dismissed.

Expenses for appeal shall be borne by the defendant.

Purport of claim and appeal

1. Purport of the claim.

1. On April 10, 2018, the Defendant’s husband’s husband’s 2015, 2016, and 2017, the global income tax for the year 2017, and the earned income tax and retirement income tax for the year 2017, the Defendant and B, who were delinquent, shall sell the real estate listed in the attached Table 1 (hereinafter “multi-family housing”) to the Defendant for KRW 400 million (hereinafter “multi-family housing”) and completed the registration of ownership transfer in the Defendant’s apartment.

At the time of the conclusion of the contract, the establishment registration of the mortgage of the debtor B, the mortgagee E, the maximum debt amount of KRW 76,70,000 was completed regarding the apartment.

[Reasons for Recognition] Each entry in Gap evidence 1 through 5 (including a serial number; hereinafter the same shall apply) and the purport of the whole pleadings

2. The establishment of a fraudulent act;

A. According to Article 21(2)1 and (3)1 of the Framework Act on National Taxes, as a preserved claim against B, the Plaintiff’s liability to pay global income tax on the person to whom the income accrued belongs is established at the end of the taxable period to which the income accrued; and the earned income tax and retirement income tax on the source are established at the time of paying the income amount. In addition, pursuant to Article 21(1)11 of the former Framework Act on National Taxes (amended by Act No. 16097, Dec. 31, 2018), the liability to pay additional tax is established at the time when the liability to pay national tax arises. Meanwhile, if a national tax claim is deemed a preserved claim, the amount of the national tax claim includes additional dues and aggravated additional dues arising from the time of closing argument in fact-finding proceedings after the fraudulent act (see, e.g., Supreme Court Decision 2006Da6753, Jun. 29, 2007).

A. The global income tax for the year 2015, 2016, and 2017 as stated in the port, and the earned income tax and retirement income tax for the year 2017 were delinquent.

[Grounds for recognition] Each entry, whole pleadings, and evidence Nos. 1 through 6.