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(영문) 서울고등법원 2011. 02. 11. 선고 2010누29712 판결

납세의무자가 아닌 자의 전말서는 보완조사 없이 과세자료로 삼을 수 없음[국패]

Case Number of the immediately preceding lawsuit

Suwon District Court 2010Guhap3504 (O. 19, 2010)

Case Number of the previous trial

Early High Court Decision 2009J3701 ( December 15, 2009)

Title

The entire end of a person who is not a taxpayer shall not be considered as a taxation data without a supplementary investigation.

Summary

A statement made by a person who is not a taxpayer in the course of investigation by an investigative agency or a tax authority is merely a unilateral statement, unless there is evidence that conforms to the statement or there is no complementary investigation such as confirmation of the facts about the taxpayer, and thus it cannot be deemed a taxation data for the taxpayer unless there are other special circumstances.

Cases

2010Nu29712 Revocation of Disposition of Imposition of Special Consumption Tax, etc.

Plaintiff

west-gu

Defendant

OO Head of the tax office

Judgment of the lower court

Suwon District Court Decision 2010Guhap3504 Decided August 19, 2010

Text

1. The defendant's appeal is dismissed.

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

Purport of claim and appeal

1. Purport of claim

The Defendant’s imposition of KRW 102,651,290 of value-added tax for the second period of August 1, 2006, and KRW 13,73,010 of value-added tax for the first period of October 7, 2007, and KRW 26,315,870 of special consumption tax for the month of August 7, 2009, and KRW 7,321,40 of education tax for the year of August 7, 2006, and KRW 39,349,60 of special consumption tax for the month of November 1, 2006, and KRW 10,957,010 of education tax for the year of 206, and KRW 31,720,390 of special consumption tax and KRW 8,823,480 of education tax for the year of December 13, 207, and imposition of KRW 305,309 of education tax for the special consumption tax.

2. Purport of appeal

The judgment of the first instance is revoked. The plaintiff's claim is dismissed.

Reasons

The reasoning of this Court is that the reasoning of the judgment of the first instance is the same as that of the reasoning of the judgment of the first instance, and thus, this Court shall accept it in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of

Therefore, the judgment of the first instance court is legitimate, and the defendant's appeal is dismissed as it is without merit. It is so decided as per Disposition.