(심리불속행) 이 사건 부과처분이 부과제척기간을 도과하여 무효인지 여부[국승]
Seoul High Court 2018Nu51289 ( November 16, 2018)
Seocho 2017west 3408 ( November 07, 2017)
(D) Whether the disposition of this case is null and void after the exclusion period for imposition is imposed.
(C) If the principal registration of this case was completed as the object of collateral security and the settlement procedure is planned, the debtor will transfer the security only when the ownership of the security was finally transferred to the creditor or a third party due to the debtor's default, etc., and then the debtor will transfer the security. Thus, the disposition that deemed the time of the principal registration of this case as the date of transfer is legitimate.
The exclusion period for national tax assessment under Article 26-2 of the Framework Act on National Taxes
2018Du64894. Invalidity of a disposition imposing capital gains tax
Park Ho-o
o Head of the tax office
Seoul High Court Decision 2018Nu51289 Decided November 16, 2018
March 29, 2019
The appeal is dismissed.
The costs of appeal are assessed against the defendant.
All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but it is clear that the assertion on the grounds of appeal by the appellant constitutes Article 4 of the Act on Special Cases Concerning the Procedure for Appeal and therefore, the appeal is dismissed under Article 5 of the above Act. It is so decided as per Disposition by