종합소득세부과처분취소
1. The plaintiff's appeal is dismissed.
2. The costs of appeal shall be borne by the Plaintiff.
Purport of claim and appeal
The first instance court.
1. The reasoning of the judgment of the court of first instance cited the following among the reasons for the judgment of the court of first instance, and it is identical to the reasons for the judgment of the court of first instance except for adding the judgment as to the matters alleged by the plaintiff in the court of first instance as set forth in paragraph (2) above, and therefore, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of
The 7th 20th 20th 7th am "the fact that withholding was made" is "the fact that there are no particular grounds to see Article 21 (1) 22 of the Income Tax Act, Article 163 (13) of the Enforcement Decree of the Income Tax Act does not apply to the stock-listed corporation like the company in this case."
The 8th 10th 10th e.g. “for events” shall be considered as “for events.”
2. Additional matters to be determined;
A. The Defendant asserted that the Plaintiff’s global income tax return was wrong, even if it was able to impose a disposition of rectification at any time, and imposed additional tax due to business delay.
Therefore, it is unreasonable that the Plaintiff is liable for the penalty tax portion, and thus, the penalty tax portion should be revoked.
B. Under the judgment tax law, where a taxpayer violates various obligations, such as a return and tax payment, as prescribed by the Act without justifiable grounds, in order to facilitate the exercise of the right to impose taxes and the realization of a tax claim, a taxpayer’s intention or negligence is not considered, but does not constitute justifiable grounds that do not cause the taxpayer’s breach of duty.
(2) The Plaintiff’s return of the global income tax for 2012, recognizing the profits from the exercise of appraisal rights at the time of sale of the instant shares, is deemed due to the site and error in the relevant statutes. The Defendant’s return of the global income tax for 2002Du10780, Jun. 24, 2004, when recognizing the profits from the exercise of appraisal rights as at the time of sale of the instant shares, is deemed to have been due to