The plaintiff's appeal is dismissed.

Expenses for appeal shall be borne by the plaintiff.

Purport of claim and appeal

The judgment of the first instance.

1. Basic facts

A. Details of the alteration of rights to the instant real estate 1) The real estate listed in the attached list (hereinafter “instant real estate”).

As to E Co., Ltd. (hereinafter “E”) on June 5, 1992

(2) On March 21, 1996, the Plaintiff completed the registration of ownership transfer on the instant real estate on February 18, 1996, when the registration of ownership transfer was completed under the name of F on April 22, 1994.

B. The Defendant’s attachment disposition, etc. regarding the instant real estate 1) on November 5, 1992, attached the instant real estate on the grounds of delinquency in local taxes E on November 6, 1992. On November 6, 1992, the attachment registration was made pursuant to the attachment (hereinafter the above attachment disposition “1 attachment disposition”), and the subsequent attachment registration is “registration 1 attachment registration.”

(2) On February 21, 2019, the Defendant seized the instant real estate on grounds of the Plaintiff’s delinquency in property tax, and registered the attachment on April 2, 2019.

(hereinafter the above attachment disposition is referred to as "Attachment 2", and subsequent attachment registration is referred to as "registration 2 of attachment".

In relation to the registration of seizure-related arrears (1) No. 1, as of April 27, 2020, regarding the registration of seizure-related arrears (1) No. 40,787,190 won (the portion of corporate tax imposed on E on May 31, 1993) for the portion for which the statutory due date has arrived before April 22, 1994, the registration of transfer of ownership in the name of F on the real estate of this case among the delinquent local tax amount of local tax E as of April 27, 2020, the Plaintiff’s delinquent local tax amount as of September 2, 2020 is KRW 865,940 (the principal amount is KRW 840,840, additional tax amount is KRW 25,100).

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, Eul evidence Nos. 1 through 4, 13, and the purport of the whole pleadings

2. Determination on the principal safety defense of the Defendant and the Intervenor joining the Defendant

A. In order to collect delinquent local taxes in arrears, the defendant issued the first attachment disposition with respect to the real estate in this case owned by E who is a taxpayer at the time. The plaintiff made the first attachment disposition with respect to the real estate in this case.