The right to complete a pre-sale agreement shall be cancelled for provisional registration at the expiration of 10 years of exclusion period.

Unless the right to the completion of the pre-sale is exercised, the right to the completion of the pre-sale agreement has already ceased to exist after the lapse of the exclusion period.

Article 24 of the National Tax Collection Act

2015 grouped 5317869 Cancellation of provisional registration

Korea

The AA

Pleadings without Oral Proceedings

December 22, 2015

1. The defendant will implement the procedure for the cancellation of the registration of the right to claim transfer of ownership, which was completed on March 9, 198 by the receipt No. 0000 of the receipt on March 9, 1988, with respect to the real estate listed in the separate sheet to Nonparty GaB.

2. The costs of the lawsuit are assessed against the defendant.

Cheong-gu Office

The same shall apply to the order.

1. Indication of claims: It shall be as shown in attached Form; and

2. Judgment without holding any pleadings: Article 208 (3) 1 of the Civil Procedure Act.

[Attachment]

Cheongwon of the Gu

1. Relationship between parties;

On September 3, 2001, the Plaintiff is the tax payer of Nonparty ParkB (hereinafter “LB”), who attached the real estate listed in the attached list on September 3, 2001, and the Defendant registered the right to claim transfer of ownership on the real estate listed in the attached list of ParkB’s attached list (Evidence No. 1, the due date for arrears, and the due date for arrears).

2. Seizure of the Plaintiff’s real estate

On September 3, 2001, the Plaintiff seized the real estate listed in the attached Table to collect the delinquent tax amount of ParkB, and the national taxes related thereto are as shown in [Attachment 1] (Evidence 1 and Evidence 2).

[Attachment 1] Delinquent amount related to attachment (base date: August 27, 2015)

(unit: Won)

List of Tax Items

Deadline for payment

Legal date;

guidance.

Internal Tax

Additional Dues

Transfer Income Tax

February 1, 1996

January 2, 1996

00,000,000

00,000,000

Transfer Income Tax

August 31, 1996

August 1, 1996

00,000,000

00,000,000

00,000,000

3. Expiration of the exclusion period;

In the unilateral promise for sale, the right of the contractor to make the trade effective by expressing his/her intention of completion of the trade reservation, that is, the right to conclude the trade reservation is a kind of right to form and exercise the exercise period between the parties, if not, within such period, and within 10 years from the time the reservation is made, and the right to conclude the reservation shall be extinguished upon the lapse of the exclusion period (see, e.g., Supreme Court Decision 2000Da26425, Jan. 10, 2003).

4. Insolvent of a debtor;

As of the date of filing a lawsuit, the active property of ParkB is as shown in [Attachment 2], but it is virtually impossible to repay due to the provisional registration of the right to claim ownership transfer based on the purchase and sale of the real estate listed in the attached Table, and it is virtually impossible to repay through compulsory execution, and the real estate listed in the attached Table is deducted from the active property regardless of the actual value of the property, and the income and property [Attachment 3] is not actually active property, and the delinquent taxpayer is in insolvent (the list of the data on the property of delinquent taxpayer, etc., the balance sheet of No. 4, the balance sheet of No. 5, and the shareholders status of

[Attachment 2] The active property of the defaulted taxpayer B as of the filing date of the lawsuit

(unit: Won)

Classification

Evaluation amount (standard market value)

Measures Restricting compulsory execution

Non-higher (owner)

[Land] Chungcheongnam-do, Chungcheongnam-do, 000-00

00,000,000

Provisional Registration of Transfer Claim Rights

December 31, 1987

Nonparty 2B

(주)ㅇㅇㅇㅇ

Unlisted 3,800 Shares

0,000,000

December 31, 2012 Closure

November 4, 2011

Nonparty 2B

Total

00,000,000

[Attachment 3] Petty Property of the defaulted taxpayer B as of the filing date of the lawsuit

(unit: Won)

Classification

Amount

Jinay

National taxes in arrears

00,000,000

(including additional charges)

Total

00,000,000

5. Exercise of rights by the defaulted taxpayer and exercise of rights by subrogation.

A. ParkB entered into a pre-sale agreement with the defendant on March 9, 198 with regard to the real estate listed in the separate sheet, and completed the registration of the right to claim ownership transfer on March 9, 198 by the defendant on March 9, 198.

B. The registration of the right to claim ownership transfer under the above paragraph (a) of this Article has already ceased to have the right to complete the sale after the expiration of the exclusion period without exercising the right to complete the sale. Therefore, the defendant is obliged to cancel the registration of the right to claim ownership transfer on the real estate stated in the attached list by way

C. As above, ParkB, who is a delinquent taxpayer, does not exercise his own right (right to claim for cancellation of the provisional registration of ownership transfer) against the defendant, so the plaintiff is not satisfied with the taxation claim of KRW 163,477,30 up to now, and ParkB also intends to exercise in subrogation the delinquent taxpayer's right to recover the tax claim through public sale pursuant to Article 61 (1) of the National Tax Collection Act, because it is judged that there is no intent to pay national taxes in arrears in the future, thereby eliminating the limitation factors of compulsory execution.

6. Confirmation of details of provisional registration;

In order to verify facts, the defendant was asked about the type of registration of the provisional registration of the right to claim transfer of ownership in this case. The defendant stated that "the person who does not know of the Seoul Regional Tax Office will leave the tax office ( August 27, 2015) for the purpose of ascertaining the fact, and that "the person who did not know of the YB will gather about the reason for failing to implement the procedure for the establishment of the provisional registration of the provisional registration and the transfer of ownership based on the provisional registration" but refused to prepare and sign the confirmation document (the statement of the provisional registration review of the provisional registration of the P

7. Conclusion

As above, the registration of the right to claim transfer of ownership by the defendant's reservation on the real estate stated in the attached list shall be cancelled at the expiration of the exclusion period. Since there is a tax claim against ParkB, and ParkB does not exercise the right to claim cancellation of the provisional registration of the right to claim transfer of ownership against the defendant, the plaintiff filed the lawsuit in this case in order to perform the registration of cancellation of the provisional registration of the right to claim transfer of ownership as stated in the attached list by subrogation of ParkB in order to satisfy the tax claims against ParkB.

[Attachment]

List

1. [Land] 312-19С-dong, New-dong, Chungcheongnam-do, Chungcheongnam-do;