1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. The judgment of the court of first instance is justifiable even if the Plaintiff’s citing the judgment of the court of first instance was examined based on the newly submitted evidence, taking into account the allegations and reasons supplemented in the trial.

Therefore, the reasoning of the judgment of this court is as follows, since it is identical to the reasoning of the judgment of the court of first instance except for dismissal or addition as follows, it refers to the reasoning of the judgment of the court of first instance.

Under the second sentence of the first instance judgment, the term “e.g., notified tax amount of KRW 245,51,074” in the sixth sentence is deemed to read “e.g., notified tax amount of KRW 247,551,074.”

Under the second sentence of the judgment of the court of first instance, the following "(hereinafter referred to as "the donation of this case") shall be added to "the donation of this case" during the second sentence.

In the fifth and third instances of the judgment of the court of first instance, “the intention of the defendant and B is presumed to be intentional” is presumed to be “the defendant, who is a beneficiary, shall be presumed to be a bad faith of the defendant.”

The following judgments shall be added to the 6th sentence of the first instance judgment.

The Defendant asserts that “B received a notice from the Busan High Tax Office on September 11, 2017 that the donation of the instant real estate was made by B to the Defendant on July 18, 2017, and thus, B and the Defendant could not anticipate the occurrence of the instant tax liability. Therefore, the Defendant did not know that the said donation constitutes a fraudulent act.” Since a certain legal act is objectively presumed to constitute a fraudulent act, the beneficiary’s bad faith is presumed presumed to have been committed. As such, the fact that the beneficiary was unaware of the fact that the beneficiary was guilty of the fraudulent act should be supported by objective and objective evidence, etc. in recognizing that the beneficiary was acting in good faith at the time of the fraudulent act, and only the obligor’s unilateral statement or a statement merely based on the third party’s reasoning, etc. should not be concluded that the beneficiary was bona fide at the time of the fraudulent act (see, e.g., Supreme Court Decision 201Da5716, Apr. 16, 2006).