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 court's explanation on this part of the reasoning of the judgment of the court of first instance is the same as the corresponding part of the judgment of the court of first instance, except where "the plaintiff" in the second six of the judgment of the court of first instance is deemed "B", and therefore, it is also accepted in accordance with the main sentence of Article 420 of the

2. The assertion and judgment

A. The plaintiff's assertion is as follows: "property tax, etc. notified until the disposal price is received" under Article 22 (1) 2 of the Trust Contract of this case (hereinafter "the provision of this case") includes the pertinent tax borne by the truster as a taxpayer in relation to each of the real estate of this case. Thus, the plaintiff's claim for the tax claim of this case directly against the defendant since the trust contract of this case is for a third party with the purport of allowing the plaintiff who is a tax payer to acquire the claim prior to the priority beneficiary, etc., and (2) as provided in the trust contract of this case and the provision of this case, as long as the truster and the trustee who is the tax obligor B are not performing the duty of settlement of the corresponding tax, they can claim the payment of the pertinent tax amount directly against the defendant, and the plaintiff can claim the payment of the settlement amount claim against the defendant who is the trustee in lieu of B in subrogation of the resolution resolution of insolvency.

(The plaintiff at the first instance court, argued that the trust contract in this case is a performance acquisition agreement that requires the defendant to perform the corresponding tax payment obligation of the B, and thus, the defendant is entitled to receive the corresponding tax payment from the defendant in subrogation of the Dispute Resolution Co., Ltd., and the cause of the claim was changed in the first instance.

Judgment

1) Article 107(2)5 of the former Local Tax Act (amended by Act No. 12153, Jan. 1, 2014) provides that a truster, who is not a trustee, shall be liable to pay property tax for any trust property registered under the name of the trustee pursuant to the Trust Act.