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(영문) 서울고등법원 2019.11.06 2018누73456

종합소득세부과처분등취소

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1. The plaintiff's appeal against the defendants is dismissed in entirety.

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

purport, purport, and.

Reasons

1. The reasoning of the judgment of the court of first instance, such as admitting the relevant part of the judgment of the court of first instance, is as stated in the grounds of the judgment of the court of first instance (excluding the part of “3. Conclusion” and “Attachment 1” and the part of “Attachment 1”, and including the relevant Acts and subordinate statutes, and therefore, it is acceptable as it is in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420

2. “In accordance with the operation of the instant building 2, 100,000 won per month from 2012 to 2014” was revised as follows: “In the course of tax investigation, from 2010 to 2011, B paid KRW 18 million per month to 200,000,000 to 3,00,000 won per month to 200,000,000 won per month to 3,000,000 won per month from 2012 to 3,000,000 won per month from 200,000,000 to 5,000,000 won from 3,00,000,000,000,000,000,000 won per month from the instant building.”

The registration of the establishment of a right to lease on a deposit basis was terminated around September 201, and around January 2012, B returned KRW 500 million when B takes over another parent.

- From January 2010, B had been entrusted with the operation of the building of this case to B on the condition that B would directly interfere with the operation of the Moel and received monthly rent of KRW 18 million.

In addition, on December 2011, B was allowed to directly take over other surrounding cartels, the direct operation of the instant building was discontinued, and the amount of KRW 3 million was exceeded due to the management (limited to management).

B’s statement - Lending KRW 500 million to the Plaintiff, and the creation of chonsegwon is more than the creation of collateral.