증여세부과처분취소
1. The plaintiff's appeal is dismissed.
2. The costs of appeal shall be borne by the Plaintiff.
Purport of claim and appeal
The first instance court.
1. The reasoning of the judgment of the court of first instance is as follows, except for the addition of some contents, and thus, it is consistent with the reasoning of the judgment of the court of first instance. Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article
The following shall be added to the 7th page of the judgment of the first instance.
【Plaintiff asserts to the effect that the burden of proof of new facts necessary to apply the amount of transfer in consideration of the acquisition of shares was on the part of the other tax authorities as the amount of KRW 257,389,600,00, which is the amount of transfer stated in the contract for stock transfer (Evidence A) was on the ground that the said amount was denied by the other tax authorities. However, in the meantime, the Plaintiff asserts to the effect that the head of both tax offices imposed capital gains tax of KRW 31,385,578, local income tax of KRW 3,138,058 on the part of KRW 257,38,600 on the part of KRW 257,38,60 on the part of the parties to the contract for stock transfer (amended by Act No. 9270, Dec. 26, 2008) was on the part of KRW 70,000 on the part of KRW 9,000 on the part of the parties to the contract for stock transfer.