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(영문) 서울고등법원 2020.01.29 2019누43094

법인세부과처분취소

Text

1. Revocation of the first instance judgment.

2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

Reasons

1. The reasons why the court uses this part of the reasons for the decision of the court of first instance are as stated in Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act, except where part of the reasons for the decision of the court of first instance is used as follows. Thus, this part of the reasons for the decision of the court of first instance

[Supplementary part] The part of the report on rehabilitation claims of the court of first instance on the 6th page 1 of the judgment of the court of first instance is the "Report on Rehabilitation Claims of the D Bank".

(g) Section 1 (g) of the first judgment of the first instance shall be made as follows:

G. Based on the Plaintiff’s report of corporate tax and the Defendant’s taxation disposition 1) on November 2, 2016, based on the results of the tax investigation under the foregoing paragraph (f) above, the Defendant revised the tax base and tax amount as described in the following [Attachment 3] (hereinafter “each correction of this case”) from 2012 to 2015.

) The corporate tax imposed on November 2, 2016, stating that the corporate tax for the business year 2012 is KRW 916,144,280,000, and the corporate tax for the business year 2015 is KRW 2,001,979,570, and the corporate tax is imposed on November 2, 2016.

[Attachment 3] The Defendant’s corporate tax base and tax amount (amount unit: KRW 201.25) were 2012 3,584,669,814, 692,060, 3714, 376, 279, 916, 283 751,609, 42324,083, 913-12, 476, 4781, 100-12,248, 152, 70, 7050-248, 205, 205, 205, 205, 305, 205, 205, 306, 305, 47, 3084, 196, 305, 205, 305, 205, 20148, 2014