1. Nonparty D on January 25, 2016:

(a) KRW 40,000,000 entered into between the Defendant A;

B. 30,000. Conclusion between Defendant B

1. Facts of recognition;

A. D’s imposition of capital gains tax on D’s 1) on November 13, 2015: (a) transferred land and buildings located in Ulsan Jung-gu, Ulsan-gu, Seoul-gu, to each transferee for KRW 2.2 billion on November 16, 2015; and (b) on November 16, 2015, the land and buildings located in Ulsan-gu, Ulsan-gu, Seoul-gu, to each transferee for KRW 2.2 billion (hereinafter “each of the instant cases”); and (c) each of the instant transferred real estate is “each of the instant transferred real estate.”

(2) On January 31, 2016, D made a preliminary return of capital gains tax on each of the instant transferred real estate (total tax amount to be paid, total of KRW 411,831,389, and total of KRW 206,831,389, among them, the tax amount to be paid, and KRW 205,00,000,000).

3) On April 21, 2016, the head of the Ulsan District Tax Office under the Plaintiff-affiliated Tax Office notified D of the payment of KRW 96,851,290,000 among the capital gains tax of KRW 206,831,389, which D first pays KRW 112,00,00,000, and notified D of the payment of capital gains tax of KRW 96,851,290 to D on April 21, 2016. The head of the Yangyang District Tax Office under the Plaintiff-affiliated Tax Office notified D of the payment of capital gains tax of KRW 207,521,50 (including additional tax) on May 21, 2016 to D on the payment of capital gains tax of KRW 207,521,500 (including additional tax) as follows at the time of filing the instant lawsuit in this case.

Tax item payment deadline (units: 96,851, 290 119, 514, 390 April 30, 2016, the transfer income tax of the amount of delinquent local taxes (including additional dues, units: won) (including the amount of local taxes), the amount of delinquent local taxes (including the amount of local taxes, unit): 304,372,79, 375,595,780 on May 31, 2016; 207,521,50 256,081, 390 on May 31, 2016;

B. D’s gift to the Defendants was received from the transferee on November 2015, and transferred KRW 40 million to Defendant A, who is a child, in his/her deposit account in his/her own name, from January 25, 2016, to Defendant B and C, each of which was donated (hereinafter “each of the instant gift”).

C. D was insolvent at the time of each gift of this case, and it did not have any property other than each transferred real estate of this case.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 6, the purport of the whole pleadings.