1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

1. The reasons for the acceptance of the judgment of the court of first instance are as follows, except for the addition of the following '2. Additional Judgment' as to the assertion that the plaintiff emphasizes or adds to this court, and thus, it is consistent with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

(a) An additional determination; 2. Additional determination

A. The interruption of prescription by the Plaintiff’s assertion becomes invalid when the seizure is cancelled or the enforcement procedure is terminated.

Although the seizure No. 1 of the instant case was not rescinded, as the Defendant collected the entire deposit amount in the Plaintiff’s B Bank account (G; hereinafter “instant account”) on June 10, 2010, and the enforcement procedure under the seizure No. 1 of the instant case was terminated, the extinctive prescription period of each tax claim of the instant case was expired again after the lapse of five years.

(hereinafter “First Claim”). Even if the execution procedure by the instant seizure had not been completed as above, the Defendant collected the entire deposit deposited in the instant account on June 10, 2010, and thus the deposit deposited in the instant account remains no longer or remains within the scope of the property subject to prohibition of seizure. As such, the instant seizure No. 1 loses its effect due to the seizure of the property subject to prohibition of seizure, and accordingly, the interruption of prescription becomes null and void. Accordingly, the extinctive prescription period of each tax claim of this case has expired again from that time, and the period of five-year extinctive prescription expired.

(hereinafter referred to as “second assertion”). (b)

1) As to the allegation No. 1, the interruption of prescription by “a seizure” among the grounds for interruption of extinctive prescription can be deemed to have expired when the seizure is rescinded or when the enforcement procedure is terminated (see, e.g., Supreme Court Decision 2016Da239840, Apr. 28, 2017). 2) As alleged by the Plaintiff, whether the enforcement procedure by the seizure No. 1 of this case has expired on June 10, 2010, as alleged by the Plaintiff.

Attachment of claims.