특별이익을 공제하고 정상적 경상이익만을 기초로 순손익가치를 함께 반영하는 방법이 합리적임[일부패소]
Seoul High Court 2012Nu12268 ( December 27, 2012)
National Tax Service Review and Transfer 2010-0259 ( October 30, 2011)
It is reasonable to deduct special benefits and reflect the net profit and loss value on the basis of the normal ordinary profit only.
It is reasonable to reflect the net value of profit and loss and the net asset value together with the net asset value in the method of calculating the market value of unlisted stocks, except in exceptional cases prescribed by the net asset value only to be assessed by the market value of unlisted stocks, with the intention of the legislators, and to reflect the weighted average value of net profit and loss for the last three years based solely on the normal ordinary ordinary profit.
2013Du2853, revocation of disposition of imposing corporate tax, etc.
-Appellant
AAA and five others, a corporation
-Appellee
Samsung Head of Samsung Tax Office, two others
Seoul High Court Decision 2012Nu12268 Decided December 27, 2012
All appeals are dismissed.
The costs of appeal are assessed against each appellant.
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 allegations on the grounds of appeal by the appellant fall under Article 4 of the Act on Special Cases Concerning the Procedure for Appeal, and all of the appeals are dismissed under Article 5 of the same Act. It is so decided as per Disposition
Reference materials.
If the grounds for final appeal are not included in the grounds of appeal that make it appropriate for the court of final appeal to become a legal trial, such as matters concerning significant violation of Acts and subordinate statutes, etc., the system of final appeal will not continue to proceed with the deliberation on the merits of the grounds for final appeal, but will not proceed with the deliberation on the merits of the grounds for final