양도소득세부과처분취소
1. The part of the plaintiff's claim that is dismissed additionally below among the judgment of the court of first instance shall be revoked.
(e).
1. Details of the disposition;
A. On August 26, 2010, the Plaintiff: (a) on August 26, 2010, purchased and sold real estate; (b) on the land of Jongno-gu Seoul Metropolitan Government (hereinafter “instant land”).
) The building of the second and second floors above the ground (hereinafter referred to as the “instant building”) and the building of the second floor above the ground, and the “instant real estate” collectively referred to as the “land and the building.”
(1) 1.2 billion won auction (Seoul Central District Court I; hereinafter referred to as “instant auction”)
(1) On December 10, 2010, the instant building was acquired as the second floor C (hereinafter “instant housing”).
(ii) Nos. 4, 2-2, 2-2, and 6 (other than the instant housing) of the 1st underground floor, the remainder of the 3-1st underground buildings are collectively referred to as the “buss shop.”
(2) On December 10, 2010, the Plaintiff transferred the instant house to G (transaction value on the register): (i) and (ii) on March 8, 2012, reported the transfer value to KRW 600,000,000 to KRW 598,197,090.
B. The Defendant shall conduct a tax investigation to impose KRW 70 million on June 3, 2013 (including additional taxes) the transfer value of KRW 383,040,60 and the acquisition value of KRW 195,80,850 (including additional taxes) on the capital gains accrued in 2010 (hereinafter “the initial imposition disposition”).
(2) On March 4, 2014, prior to the determination by the Tax Tribunal, the Plaintiff filed an appeal with the Tax Tribunal, and the necessary expenses additionally confirmed are included in the acquisition value, and KRW 11,089,200 of the initial disposition was ex officio reduced (the total amount of the final tax, including additional tax, KRW 184,715,650).
On April 8, 2014, the Tax Tribunal rendered an adjudication decision stating that “The initial disposition of imposition by the tax Tribunal shall rectify the tax base and tax amount with the transfer value as KRW 600 million, and the remaining appeal shall be dismissed.”
On May 22, 2014, according to the decision of the Tax Tribunal on May 2, 2014, the Defendant additionally reduced the tax amount of KRW 65,515,00 (the total final tax amount, including additional tax, KRW 119,20,650).
On April 10, 2014, the Plaintiff made a decision to judge by the Tax Tribunal.