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(영문) 서울고등법원 2018.12.06 2018누64902

법인세부과처분취소

Text

1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

Reasons

1. The reasoning of the judgment of the court of first instance, which cited 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 case where the reasoning of this case is written as stated in paragraph (2). Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act

2. The portion of "Plaintiff" in the 7th 11 line, written in height, shall be changed to "B".

7 The part of "the question and answer of July 1, 2016" of one column of "the answer of July 1, 2016 (Evidence B (Evidence B) and August 10, 2016 (Evidence B (Evidence 5) of "the questioning of the suspected criminal suspect")" shall be read as "the answer of July 1, 2016 (Evidence B)".

8 Under 8, 5 lines “B is conducting automobile information provision business and insurance agency business,” the part “B, from the time of establishment to October 20, 2014, was intended with automobile sales agent business and automobile information provision business, etc., and from October 21, 2014, deleted automobile sales agent business from the purpose business to the purpose business and added the insurance agent business to the purpose business.”

9 The part of "O agency (P)" of 7 lines in the 9th letter box shall be " Q agency (R)".

11. The part of “the Defendant’s audit” of the 11st line shall be regarded as “B’s audit.”

11. After the fourth line, “P, who is an employee of each sales agency that has entered into a motor vehicle purchase contract with the Plaintiff, and R does not explain how the external auditor E has played a specific role in B, and only reply is made to the effect that it has paid sales incentives to B, taking into account the trust relationship with the Plaintiff’s representative director who has continuously engaged in transactions with the Plaintiff.”

11 The part of "provision of vehicle information" of 7 lines at the bottom of the 11st is "Provision of vehicle purchase information by the plaintiff".

11 The part “not B” of two lines under the bottom shall be read as “B’s audit.”

13. The portion of "a point which appears to have formed the appearance such as receiving the disputing source" of the 12th line is "a point of dispute."