1. The defendant's appeal is dismissed.

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

3.Paragraph 1 of the text of the judgment of the court of first instance.

1. Facts of recognition;

A. B is in arrears with the transfer income tax of KRW 227,288,810 as of May 13, 2015 (Jurisdiction: Dongyang Tax Office) as shown in the following table:

Tax item code management number year;

27,288,810,810 won from the occasional notice of 158,732,340 won on December 17, 2012, capital gains tax of 227,28,288,810 won, 7,340 won from the time limit for payment of additional education tax for the tax item of special rural and rural development tax. 60,898,470 won from 7,658,00 won

B. On September 7, 2002, B completed on September 7, 2002 the registration of Ulsan District Court and the registration of the right to claim transfer of ownership under No. 92794 on the same day with respect to the shares owned by the Defendant among the real estate listed in the separate sheet (hereinafter “each of the instant forests”) as the grounds for registration.

(hereinafter “the provisional registration of this case”) C.

B On July 28, 2015, in the course of the lawsuit of the first instance court, the Defendant completed the principal registration based on the provisional registration of this case with respect to the shares owned by himself among the forest of this case.

In other words, on July 28, 2015, the Defendant: (a) based on the provisional registration of this case on July 24, 2015, the grounds for registration was to sell and purchase the forest land as of July 24, 201; (b) the registration of the Ulsan District Court and the registration of the transfer of ownership as to each forest land listed in the Nos. 1, 2, and 3 of the forests of this case was completed under the Ulsan District Court No. 16678; and (c) the registration of the transfer of ownership as to each forest land listed in

(hereinafter “instant transfer registration”) C.

On the other hand, on September 7, 2002, B completed the registration of ownership transfer as to 1/2 of the forest land of this case based on the final judgment of Seoul Central District Court 99 Gohap3569 on September 7, 200.

(F) Shares of F, G, and H 1/6, total of 1/2 shares, and total of 1/2 shares in each forest of this case: Provided, That each shares of F, G, and H were seized on July 15, 2002, prior to the completion of the above ownership transfer registration, with respect to each forest of this case, the forest of this case was attached.

However, the forest land of this case 1, 2, and 3 are related to each forest land of this case.