1. Revocation of the first instance judgment.

2. As to the 3/7 share of each real estate listed in the separate sheet 1 between the defendant and B.

1. Basic facts

A. The Plaintiff’s taxation claim B against Nonparty B runs wholesale and retail business, such as office equipment, in the name of “F” from around 1999 to 2003. As of October 2016, national taxes in arrears amounted to KRW 342,785,190 in total as indicated below.

B. The instant agreement on division of inherited property and G, the spouse of Nonparty B’s insolvent 1) B (hereinafter “the deceased”).

(2) On October 13, 2014, the deceased on October 13, 2014, the heir died, and there was B (3/7) who is the spouse, Defendant (2/7), and H (2/7). B, Defendant, and H completed the registration of ownership transfer on October 13, 2014 with respect to each real estate listed in the separate sheet No. 1 and each real estate listed in the separate sheet No. 2 (hereinafter referred to as “each real estate of this case”) listed in the separate sheet No. 2 of the deceased’s ownership on October 13, 2014. Accordingly, the agreement on division of inherited property (hereinafter referred to as “instant agreement on division of inherited property”). As to each real estate listed in the separate sheet No. 1 as of December 23, 2014; and each real estate listed in the separate sheet No. 2 of the separate sheet No. 1 as of December 18, 2014.

3) At the time, Nonparty B was in excess of his/her tax liability as above. (c) On December 23, 2014, the Defendant sold at KRW 300,000,00 of the real estate listed in the attached Table 2, Nos. 106, 1802 (hereinafter “instant C Apartment”) to I, among the real estate listed in the attached Table 2, for KRW 300,000,00, and on January 28, 2015, the ownership transfer registration for the instant C Apartment was completed in the name of I.

2) On July 3, 2015, the Defendant: (a) among the real estate listed in the separate sheet No. 2 attached on July 3, 2015; (b) Seo-gu, Gwangju; and (c) No. 101 Dong 402 (hereinafter “instant E apartment”).

As to the maximum debt amount, 120,000,000 won, the Industrial Bank of Korea of the mortgagee, and the debtor, completed the registration of creation of a mortgage on the part of the debtor. [Grounds for recognition] Gap evidence 1 through 7 (including each number.