1. The attachment disposition against each of the deposit claims listed in attached Table 1 that the Defendant rendered to the Plaintiff on August 16, 2017 is revoked.

2.

1. Details of disposition;

A. On March 20, 2014, the Plaintiff entered into a sale-type land development trust agreement (hereinafter “instant trust agreement”) with the Nonparty Company B (hereinafter “Nonindicted Company”) with the content that the Plaintiff was entrusted with the land of Seongdong-gu, Changwon-si (hereinafter “instant land”). The Plaintiff newly constructed a building on the above land and sold, leased, managed, and sold the land and the building as trust property, and thereafter, returned the profits therefrom to the truster and the Nonparty Company, the beneficiary, as the truster and the beneficiary.

B. In accordance with the instant trust agreement, the Plaintiff registered the transfer of ownership in the name of the Plaintiff, and newly constructed a building on the ground of the instant land and issued a tax invoice to Nonparty Company, the truster, as a supplier, while selling it in units.

Based on the above tax invoice, the non-party company made a preliminary return of value-added tax for the first term of 2017.

C. On August 16, 2017, the Defendant issued a seizure disposition against each of the deposit claims listed in attached Table 1 in the name of the Plaintiff on the ground that the non-party company did not pay value-added tax 1,762,218,860 for the first term portion of the year 2017.

(hereinafter “instant disposition”). D.

The Plaintiff filed a tax appeal against the instant disposition on November 9, 2017, but the Tax Tribunal dismissed it on October 31, 2018.

[Reasons for Recognition] Unsatisfy, Gap 1-4 (including a provisional number), the purport of the entire pleadings

2. Whether the disposition of this case is legitimate;

A. The Plaintiff’s assertion 1) Although the non-party company, the truster, imposed value-added tax on the non-party company based on the sale of new buildings under the instant trust agreement on the premise that the non-party company is liable to pay value-added tax, it seized the Plaintiff’s property to collect delinquent taxes for the non-party company. Thus, the instant disposition is unlawful.