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(영문) 수원지방법원 2015.12.09 2015구합241

법인세부과처분취소

Text

1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

Reasons

1. Details of the disposition;

A. From around 1974, the Plaintiff engaged in livestock farming business with the trade name of “A” in Pyeongtaek-si B, which was owned by the Plaintiff (hereinafter “B”), from around 1974, with the trade name of “A”. From around 2001, the Plaintiff closed the livestock industry and leased B-type land to C, etc. from around 2003.

On the other hand, around April 15, 2013, the Plaintiff changed its trade name to “Agricultural Company A”.

B. The director of the Seoul Regional Tax Office, from August 2012 to November 2012, conducted an integrated investigation into corporate tax against the Plaintiff, and notified the Defendant of the taxation data that the Defendant should include the aggregate amount of the property tax, comprehensive real estate tax, and interest paid (hereinafter “instant taxable period”) generated from 2007 to 2011 regarding the land subject to separate taxation and separate cumulative taxation based on the details of taxation on the aggregate land tax between the year 207 through 2011 prepared by the head of Pyeongtaek-si to impose property tax (hereinafter “instant land”).

Details of non-Inclusion of non-deductible assets in business year (original) 207 408,613,750 61,617,630,630 2,903,903,423,134,822 208 624,368,540,540,540,490,490,33333,602,2002, 207466,6046,604,6046, 6046, 604, 604, 206, 206 333,289, 289, 2010, 40, 405, 25464, 365, 25464, 206, 206, 2010, 250, 36364, 1964, 25465

C. Accordingly, on January 2, 2013, the Defendant notified the Plaintiff of the correction of KRW 287,882,820 of the corporate tax for the year 2007, KRW 480,272,250 of the corporate tax for the year 2009, KRW 116,33,550 of the corporate tax for the year 2010, KRW 720,870 of the corporate tax for the year 201, respectively.

(hereinafter “instant disposition”) D.

The Plaintiff is dissatisfied with the instant disposition and on March 2013.