과세처분취소
1. All of the plaintiffs' claims are dismissed.
2. The costs of lawsuit are assessed against the plaintiffs.
1. Details of the disposition;
A. The Plaintiffs purchased and sold a number of real estate (multi-family housing) as indicated in the table below, and thereafter acquired “D” apartment and “F” apartment located in Daegu apartment located in Daegu from 2010 to 2014, and subsequently reported transfer income tax reduction by 100% pursuant to Article 98-5 of the Restriction of Special Taxation Act.
B Transfer Acquisition by Transfer A during the taxable year 2002 3 3 17 6 2003 1 4 2004 2 2004 2 1 2006 1 2006 2 1 2007 21 2007 21 2007 21 2008 22002 231 2010 26 201 201 201 6 2015 201 201 6 201 201 201 32014 404 28
B. The director of Busan Regional Tax Office conducted a tax investigation on the Plaintiffs, and notified the Defendant of the result that the Plaintiffs continued to acquire and transfer a large number of real estate between 2011 and 2014.
C. Accordingly, the Defendant notified the Plaintiffs of the value-added tax (including additional taxes; hereinafter the same shall apply) and comprehensive income tax on the Plaintiff B from 2011 to 2013 as indicated in the following table, and the value-added tax and comprehensive income tax on the Plaintiff A from 2011 to 2014, respectively, on the ground that the Plaintiffs transferred the apartment of 31 household (hereinafter “instant apartment”) from 2011 to 2014 while engaging in real estate business for profit.
(1) The Plaintiff’s global income tax for the year in which the Plaintiff’s global income tax for the following reasons is included: (a) the global income tax for the year in which the Plaintiff’s global income tax for the following reasons is included; (b) the global income tax for the year in which the Plaintiff’s global income tax for the following reasons is included; (c) the global income tax for the year in which the Plaintiff’s global income is included; and (d) the total amount of KRW 141,876,970,970,5050,5050,960,0000,0000 and KRW 28,030,50,000,000,0000,0000,000,000,000,000,50,50,960,0000,000,000,0000,0000,0000,000,0000,000
D. The Plaintiffs were dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on January 25, 2017, but was dismissed on April 24, 2017.
[Reasons for Recognition]