1. Revocation of a judgment of the first instance;

2. As to the director of the tax office of distribution on October 12, 2012, the Defendant limited the amount of KRW 22,412,316,030.

1. The facts under the distribution of the proceeds from the sale of a public auction are either in dispute between the parties, or acknowledged by considering the overall purport of the pleadings as a whole in the entries in Gap's 1 to 4, and Eul's 1 to 3.

[1] Around November 2006, the Seoul High Court judgment that collected approximately KRW 17.923.5 billion from the Plaintiff was rendered, and this judgment became final and conclusive around that time.

Around December 2007, the Prosecutor General entered into an agreement with Defendant Korea Asset Management Corporation on the public auction of delinquent property, including fines, on behalf of the public prosecutor. In this Agreement, the public auction of the property attached by the public prosecutor due to delinquency in payment of additional charges, etc., and the transfer of rights and the distribution of sale proceeds therefrom, stipulated the standards and procedures for performing duties on behalf of the defendant.

On June 17, 2008, the prosecutor of the Seoul Central District Prosecutors' Office seized 7,767,470 shares of "B" owned by the Plaintiff (hereinafter "the shares of this case") to execute the above additional collection judgment against the Plaintiff.

The defendant joining the defendant (the chief prosecutor of the Seoul Central District Prosecutors' Office) decided to execute the above additional collection judgment in the same manner as delinquent national taxes are collected in accordance with the National Tax Collection Act, and had the defendant act on behalf of the defendant for the public sale of the shares in this case, transfer of rights and distribution of sales proceeds therefrom.

Accordingly, the Defendant publicly announced the public sale of the instant shares on December 30, 2009, and decided to sell the instant shares to C on August 6, 2012.

C paid all the sales price of the instant shares by September 13, 2012.

[2] On September 21, 2012, the director of the tax office made a decision of occasional assessment of KRW 21,759,530,130 on September 26, 2012 on the grounds of the transfer of the instant shares to the Plaintiff on September 26, 2012, for which the payment deadline was made on September 26, 2012.

Then, on September 27, 2012, the director of the tax office requested the defendant to deliver the purchase price of the shares of this case under the following tax claims.

The statutory deadline shall be April 2009.