증여세부과처분취소
1. The disposition of imposition in the attached Form that the Defendants issued against the Plaintiffs shall be revoked.
2. The costs of lawsuit shall be.
1. Details of the disposition;
A. On December 20, 2007, I Co., Ltd., an unlisted corporation (hereinafter “instant merger”) merged J Co., Ltd. (hereinafter “instant merger”) (hereinafter “instant merger”), which was the unlisted corporation, changed the name of the corporation to K Co., Ltd. (hereinafter “instant merger”).
B. In the process of the above merger, the merger ratio was determined as 0.4 shares of the instant merger company with the registered common shares of the instant merger company, and there was no separate payment of the merger subsidy or additional payment of the capital.
C. As indicated below, the Plaintiffs held 257,143 shares of the merged company of this case, which was held in title trust by Nonparty L prior to the merger of this case (hereinafter “the merged party”). As a result of the merger of this case, the Plaintiffs were allocated a total of 102,857 shares of the instant company (hereinafter “instant new shares”) instead of the instant merger party pursuant to 0.4.
[ table] Serial 1 A 25,000 shares 10,000 shares for the conversion of the real name of the merged shares of the Plaintiff 25,000 shares for the merger of the Plaintiff 3 C 25,000 shares 10,000 shares for December 29, 2008 3 C 25,000 shares for 75,000 shares for 30,000 shares for 4 D 57,143 shares for 22,857 shares for 22,857 shares for E 50,500 shares for 20,000 shares for 6H 25,000 shares for 10,000 shares for F25,000 shares for 725,000 shares for 10,000 G25,000 shares for 10,000 shares for 10,000 shares for 10,008 shares for 2718 shares
D. On December 29, 2008, Plaintiff A, B, and C (hereinafter “Plaintiff A et al.”) filed a return on gift tax pursuant to the title trust for each of 25,000 shares (total 75,00 shares) of the instant new shares of the instant merger that were issued by the instant merger on December 29, 208, on the ground of termination of the title trust, on the conversion of the real name in L’s name (total 30,00 shares) on the ground of termination of the title trust.
E. Seoul Regional Tax Office: 2010
1. As to the instant company from 20. to April 1, 2010, the period from 2004 to 2008.