1. The defendant's appeal is dismissed.

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

Purport of claim and appeal

1...

1. The reasoning of the judgment of the court of first instance concerning this case is as stated in the reasoning of the judgment of the court of first instance, except for modification as follows. Thus, this case shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420

(A) If the Defendant’s assertion and evidence submitted by this Court are examined, the fact-finding and judgment by the first instance court is reasonable). On the fourth instance judgment, the following is added to the fourth instance judgment.

Meanwhile, the preparation of attachment report in relation to the attachment of a claim under the National Tax Collection Act is merely recording and proving the fact that the relevant claim was seized within the tax authority, and it cannot be deemed an effective requirement for the attachment of a claim (see Supreme Court Decision 84Do855, Aug. 21, 1984). Thus, the attachment of a claim cannot be deemed null and void on the ground that the attachment report was not prepared, on the ground that the attachment report was not prepared. However, the obligor (hereinafter “third obligor”).

(1) In light of the language and text of the notice of attachment of claims against a third-party debtor, the attachment of claims is invalid unless the seized claim is specified or the text prohibiting the performance of obligations against a delinquent taxpayer is written (see, e.g., Supreme Court Order 72Ma59, Nov. 26, 197; Supreme Court Order 95Da41611, Apr. 22, 1997). Such legal principle also applies to the attachment procedure of a local government’s penalty, charge for compelling the performance, charge for compelling the performance, etc. applicable under the Act on the Collection, etc. of Local Non-Tax Revenue Revenue (see Article 19 of the Act on the Collection, etc. of Local Non-Tax Revenue Revenue). The effect of attachment of claims as part of the disposition on default should be objectively and uniformly determined, and even if the third-party debtor is identical to the obligee (creditor).