증여세부과처분취소
1. On April 8, 2013, the head of the Namcheon District Tax Office imposed gift tax on the Plaintiff A on April 8, 2013. < Amended by Act No. 7291, Dec. 2, 2004>
1. Details of the disposition;
A. C Co., Ltd. (hereinafter “C”) was incorporated on February 26, 2002 for the purpose of preparing, importing, and selling medicines using cell culture technology of Posibab (HIV) and other drugs (HIV), which were merged into D Co., Ltd. on August 21, 2008.
B. Plaintiff A served as the representative director of C from the time of establishment to the time of dissolution, and Plaintiff B served as the registration director of C from the time of establishment to March 2006.
C. During the offering of new shares by C over three occasions in 2004 and 2005, Plaintiff A acquired KRW 5,000 per share by being allocated the total amount of 1,866,363 shares that other shareholders renounced (hereinafter “instant 1 shares”). Plaintiff B acquired KRW 725,776 shares for the second offering of new shares (hereinafter “instant 2 shares”), and acquired KRW 5,000 per share by being allocated the forfeited shares for the second offering of new shares.
(3. 08. 1. 1. 1. 2. 1. 2. 4. 1. 6 . 1. 2. 4 . 6 . 4. 6 . 1. 6 . 4. 6 . 1. 6 . 4. 1. 6 . 4. 1. 6 . 1. 6 . 4. 1. 1. 2. 4 . 1. 1. 1. 1. 1. 1. 1. 3. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 2. 1. 1. 1. 1. 1. 1. 1. 1. 2. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1.
D. On August 16, 2005, Plaintiff A purchased KRW 7,000 per share of KRW 251,757 shares of Plaintiff B (hereinafter “instant 3 shares”) from Plaintiff B, and combined with the instant 1,2 shares (hereinafter “each of the instant shares”).
E. The Defendants shall conduct a tax investigation from October 23, 2012 to December 21, 2012 and notify the Commissioner of Central Regional Tax Office thereof.