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. Facts of recognition;

A. On July 4, 2014, the Plaintiff, the business partner of the Plaintiff, entered C’s account number, the representative of the Plaintiff’s transaction partner B, in error, and remitted KRW 16,500,000 to the Agricultural Cooperative Deposit Account (hereinafter “the instant deposit account”) in the name of C.

B. On May 27, 2015, the Plaintiff filed a lawsuit against C seeking restitution of unjust enrichment with Seoul Southern District Court Decision 2014Gao499394, and the above court rendered a favorable judgment against C to the Plaintiff to pay KRW 16,50,000 and damages for delay thereof. The above judgment became final and conclusive.

C. On July 20, 2015, the director of the Gangseo District Tax Office under the Defendant’s jurisdiction (hereinafter “the director of the Gangseo District Tax Office”) defaulted on value-added tax of KRW 173,773,470, and thus, attached the amount until the delinquent amount including the amount to be deposited at the present and in the future in relation to the instant deposit account in arrears under the National Tax Collection Act.

On August 19, 2015, agricultural cooperatives paid the remainder of 15,018,320 won, excluding the remainder of 1,500,000 won, which is prohibited from seizure, to the Defendant, and the Director of the Gangwon Tax Office appropriated the remainder of 15,018,320 won to the delinquent tax amount of C.

[Ground of recognition] Facts without dispute, Gap evidence 1 to Gap evidence 7, Eul evidence 1, Eul evidence 2, Eul evidence 2, the purport of the whole pleadings

2. Judgment on the plaintiff's assertion

A. The Plaintiff’s assertion that the amount of money erroneously remitted to the instant deposit account was planned to be returned to the Plaintiff. C was already closed on May 15, 2013, prior to the date of remittance of the Plaintiff’s mistake and was unlikely to make a transaction through the instant deposit account. The director of the Gangseo-gu Tax Office could not expect the transfer of money to the instant deposit account because he was well aware of C’s discontinuance of business, which had the domicile in the Seoul Gangseo-gu District Tax Office, with the address in the Seoul Gangseo-gu District Tax Office. Thus, the Defendant, who should protect the Defendant’s property right, was originally using the