종합소득세등부과처분취소
1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. The Plaintiff worked in a bank from March 8, 1982 and retired on January 22, 2009 (class manager at the time of retirement). The Plaintiff is qualified as a credit analysis agent, a loan examination station, and a credit examination specialist.
B. The Plaintiff provided consulting services on the method of transferring schools and changing loans to B and C from 2011 to 2015, and received KRW 562 million.
The Plaintiff reported KRW 550 million among its income (hereinafter “instant amount”) as “business income” as shown in the table below.
[ table] (unit: 314,00,000,000 business income for the year 201 as necessary expenses for the business income for the year 201 25,000 business income for 253,808,49260,191,508 business income for the year 2012 5,000,000 business income for 52,761,91222,238,0888,000,000 business income for 2013,128,488,871,512, 2014 business income for 90,000,000 business income for the year 209,275,8410,724, 1599,250,000 business income for the year 25,000,306,3046,6369,6966
C. From April 13, 2017 to May 22, 2017, the Defendant requested the Plaintiff to submit documentary evidence of the amount appropriated as necessary expenses, while conducting a tax investigation with respect to the Plaintiff, but the Plaintiff failed to submit relevant documentary evidence.
On April 18, 2017, the Plaintiff during the tax investigation period, divided the instant amount into “other income” and filed a revised return by applying 80% necessary expenses. D.
On July 3, 2017, the Defendant: (a) deemed the instant amount as business income; (b) deemed the Plaintiff’s act constituted fraud or other unlawful acts; and (c) imposed global income tax of KRW 101,112,050 (including additional tax of KRW 47,51,279); (d) global income tax of KRW 5,895,921; and (e) global income tax of KRW 3,475,512; (b) global income tax of KRW 9,172,907; and (c) global income tax of KRW 928,155,155 of global income tax of year 201 on the Plaintiff.
(A) The Plaintiff stated only the part disputing the instant lawsuit, and all hereinafter collectively referred to as “instant disposition”). 【No dispute exists, A’s evidence Nos. 1, 2, 3, and 3.