1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim

1. Attached Form B between the defendant and B.

1. The reasoning of the judgment of the court of first instance cited this case is that the reasoning of the judgment of the court of first instance is the same as that of the judgment of the court of first instance, except for the following modifications:

[Corrections] The following shall be added to the third letter 15 of the first instance judgment:

“3) The extinctive prescription of the global income tax claim on B claimed by the Plaintiff as the preserved claim was completed by the lapse of five (5) years.

[Attachment 1] The existence or absence of the preserved claim against B is as seen earlier by the Plaintiff, as of February 8, 2018, with respect to global income tax (including additional dues) 719,416,590 won in arrears as of February 8, 2018.

On the other hand, on May 18, 2018, the Plaintiff paid KRW 55,682,510 among the global income tax attributed to B in 2003.

Therefore, barring special circumstances, there are KRW 663,734,080 (=719,416,590-5,682,510) for preserved claims against B as of the time of the above payment (i.e., KRW 763,734,080).

B) As to this, the Defendant’s defense that the Plaintiff’s global income tax claim for 2003 was extinguished by prescription. However, according to the evidence Nos. 1 and 2, the Plaintiff’s notice of payment by the head of Seodaemun-gu Tax Office as of May 31, 2008 on the payment deadline of global income tax for 2003 as of May 31, 2008 is recognized. Furthermore, the Plaintiff’s lawsuit was filed on February 8, 2018 (Article 27(1)2 of the Framework Act on National Taxes and Article 12-4(1)2 of the Enforcement Decree of the same Act) after the lapse of five years from June 1, 2008 from the date following the said payment deadline (Article 27(1)2 of the Framework Act on National Taxes and Article 12-4(1)4 of the Enforcement Decree of the same Act prior to the expiration of the extinctive prescription period, according to the Plaintiff’s entry in the evidence No. 14, the Plaintiff’s land owned B15, etc.