양도소득세부과처분취소
1. The Defendant imposed a total of KRW 472,375,030 on the Plaintiff on September 2, 2013, respectively.
1. Details of the disposition;
A. D shop’s “D shop” located in Jung-gu Seoul, Jung-gu, Seoul and C was constructed around 1970 as one building with the 6th floor above ground and the 4th floor above ground.
Each of the above buildings was registered as an aggregate building for each section of exclusive ownership at the time, but the B-1,395 square meters and C-843 square meters, which is the relevant site, did not register the right to a site for the reason that the owner is different. Since the Republic of Korea completed the registration of initial ownership of each of the above sites on October 4, 1980, D had a different state between the owner of the building and the owner of the site.
B. On May 2, 1991, the Plaintiff acquired shares of 2.86/25/25.8 shares of 551 square meters and 57.32 square meters and 551 square meters and 19.1050/38.21 square meters and 538.24 November 24, 1993, and shares of 2.86/25.8 square meters and 201 square meters and 5.27 May 27, 1998.
C. As above, since the Republic of Korea had been the owner of the land D, D Co., Ltd. including the Plaintiff paid rent or indemnity for the use of the land to the Republic of Korea, the Republic of Korea around December 30, 2009 determined the said D Co., Ltd.’s default on the building site B and C, and the Plaintiff purchased the shares of B from the Republic of Korea on December 30, 209 and the shares of C Co. 6.8/843 from C Co., Ltd. totaling KRW 180,17,010 (= KRW 47,843,790) and completed the registration of ownership transfer on January 27, 2010. < Amended by Act No. 1032, Dec. 30, 2009>
Since then, the Plaintiff transferred D's shares of heading 201, 538, and 551 and shares of each of the above buildings B and C corresponding to the shares of each of the above buildings as follows:
(1) The term "land purchase price (2.86) of the land of a building on the date of the registration of transfer of ownership (the purchase price of the plaintiff) on the date of the conclusion of the sale contract (the purchase price of the plaintiff) purchase price (the purchase price of the other party to the transaction) of the subject matter of sale (2.86), shall be determined on July 1, 2010. < Amended by Presidential Decree No. 10358, Jul. 2, 2010> 122,50,000 for EF 122,50,500 for 67,500,000 (64,114,280) for EF 1,50.