Whether the Plaintiff is eligible to seek revocation of the attachment disposition against the purchaser of the seized real estate after the attachment registration based on the disposition of national tax in arrears (negative)

A person who purchased the seized real estate after the registration of seizure based on the disposition of national tax in arrears has a de facto and indirect interest in the above seizure disposition, and there is no standing to seek revocation of the above seizure disposition or confirmation of invalidity.

Article 1 of the Administrative Litigation Act

Plaintiff 1 et al., Counsel for the defendant-appellants of the Yellow River.

Head of Mapo Tax Office

Seoul High Court Decision 82Gu83 delivered on November 8, 1982

All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

The grounds of appeal are examined.

According to the reasoning of the judgment below, the court below determined that the real estate of this case was originally owned by the non-party, but the plaintiff 1 completed the provisional registration on February 20, 1979, which was based on the provisional registration on March 5, 1979, and completed the registration of ownership transfer in the name of the non-party 28 on the ground of December 26 of the same year from the above plaintiff 1. The defendant completed the registration of ownership transfer in the name of the non-party 28 of the same month on August 16, 1977. The defendant did not pay the above non-party's total income tax and defense detailed disposition on September 15, 1978 and registered the seizure on the real estate of this case on the ground of the non-party 1's default of national tax payment, and it did not err in the misapprehension of the legal principles as to the above imposition of taxes on the non-party 1, the above non-party 1, but was notified to the same person on February 14, 1979.

The issue is groundless.

Therefore, all appeals are dismissed, and the costs of appeal are assessed against the losing party. It is so decided as per Disposition by the assent of all participating judges.

Justices Lee Jong-soo (Presiding Justice)