종합소득세등부과처분취소
1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. The Plaintiff borrowed money from around 2005 to the end of 2011 to received interest from the borrower. The details are as follows.
(1) The amount of 0,00,000 won for 10,000,000,000 won for 30,00,00,000,000,00 for 141,79,790,000,000 for 20,000,000 67,805,00 25,495,000 93,30,000,00, 60,60,60,000, 60,000, 60, 6366,000, 70,000 for 0, 636,000, 70,000 for 0, 706, 36,000, 736,0000, 739, 736,000, 730,0008, 739,0004
B. On April 12, 2013, the Defendant considered the Plaintiff’s income under a interest agreement between the Plaintiff and the borrower as interest income, which is a profit from a non-business loan under the Income Tax Act, and calculated the unreported real estate rental income as a estimation. On April 12, 2013, the Defendant imposed the Plaintiff the global income tax of 50,376,200, global income tax of 2011, global income tax of 38,275,680, global income tax of 2010, global income tax of 36,118,930, global income tax of 29,341,650, global income tax of 208, global income tax of 207, global income tax of 29,242,720, global income tax of 206, global income tax of 36,256,520, global income tax of 205, global income tax of 3075,670 (including penalty tax).
C. The Plaintiff appealed and filed a request for examination with the Commissioner of the National Tax Service on June 5, 2013, but was dismissed on September 4, 2013.
[Reasons for Recognition] Facts without dispute, Gap evidence Nos. 1, 2, 3, Eul evidence Nos. 1 and 2 (including each number), the purport of the whole pleadings
2. Whether the instant disposition is lawful
A. The Plaintiff’s assertion has been running a payment business for many unspecified persons since 2005, and has lent a total of KRW 2.5 billion to 40 persons from 2005 to 2011. In light of the number of borrowers and the amount of loans, the Plaintiff’s assertion continues, repeated, and long-term profits.