The judgment of the first instance shall be revoked.

The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

purport.

1. Basic facts

A. From 2016 to the time of the filing of the instant lawsuit, F Co., Ltd. (hereinafter “Nonindicted Corporation”) did not pay a total of KRW 129,57,150, including additional dues of KRW 23,970,370, as shown in attached Table 1, as shown in attached Table 1.

B. While examining the current status of the shareholders of the non-party corporation, the head of the Gyeonggi-si Tax Office under the Plaintiff confirmed that B holds 100% of the equity shares of the non-party corporation, and sent a notice of payment to B as of April 10, 2019 pursuant to Article 39 of the Framework Act on National Taxes, after designating B as the secondary taxpayer, and the said notice of payment was served as of April 16, 2019.

C. B is liable for secondary tax liability for the portion of the arrears related to the return of the value-added tax established on January 2018, 2018, because the stocks of the non-party corporation were transferred to G as of August 20, 2018. The amount of arrears in B is KRW 109,730,820 as shown in attached Table 2.

On the other hand, B concluded a donation contract with the Defendant on April 18, 2019 with respect to the instant real estate held as the reason of the sale and purchase on September 22, 2007 (hereinafter “instant sale and purchase contract”), and completed the registration of ownership transfer based on donations in the future of the Defendant.

E. B at the time of the conclusion of the above gift contract, small property as indicated below was in excess of the obligation exceeding the positive property.

The fact that real estate of this case, active property of this case, real estate of this case, real estate of this case, real estate of this case, 98,000,000 (1) 98,000,000,000 shall be the maximum debt amount of national tax of this case, 109,730,820 (2) 174,730,820 (174,730,820) / [based on recognition] / The entry of evidence No. 1 (including the serial number) and the purport of the whole oral argument

2. The parties' assertion

A. The plaintiff's assertion has a tax claim against B. Since B has donated the real estate of this case, which is the only property under excess of the debt after the establishment of the tax claim, to the defendant, this constitutes a fraudulent act.

(b).