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(영문) 서울고등법원 2016.05.04 2015누53222

법인세부과처분취소

Text

1. Revocation of a judgment of the first instance;

2. The Defendant’s corporate tax on September 2, 2013 against the Plaintiff on September 2, 2011,569.

Reasons

1. The court's explanation concerning this part of the disposition is identical to the corresponding part of the judgment of the court of first instance (the corresponding part of the judgment of the court of first instance No. 2, No. 5 and No. 4, No. 3). Thus, the court's explanation as to this part is accepted in accordance with Article 8 (2

(hereinafter the meaning of the terms used in this case is the same as that of the first instance judgment). 2. Whether the disposition of this case is lawful or not

A. The court's explanation on this part of the plaintiff's assertion is identical to the corresponding part of the judgment of the court of first instance (section 4, 6, 7, and 12). Thus, this part is cited in accordance with Article 8 (2) of the Administrative Litigation Act, and the main sentence of Article 420 of the Civil Procedure Act.

B. The reasoning for the court’s explanation on this part is as stated in the corresponding part of the judgment of the court of first instance (from No. 13 to No. 19). Thus, this part is cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

C. The reasons why this court should explain this part of the facts of recognition are the same as the corresponding part of the judgment of the court of first instance (from No. 5 to No. 3 to No. 6) except for the following matters, and therefore, it shall accept it in accordance with Article 8(2) of the Administrative Litigation Act, the main sentence of Article 420 of the Civil Procedure Act.

From the 6th judgment of the first instance court, the part "(based on recognition)" of the 6 and 7th judgment is as follows.

[6] Around November 2009, the Plaintiff proposed to take over the instant shares at the level of KRW 2.5 billion, which is the value calculated by net asset value of the instant shares, to Doo-young Co., Ltd. (hereinafter “Doo-young”), and Doo-young sought the question of whether E can continue to supply drugs to D University Hospital for review.

Accordingly, the D University Hospital responded that “E’s contract for the supply of medicines to the D University Hospital may extend the term of the contract every year on condition that the deposit amount of KRW 60 billion is deposited.”

Laos are difficult to procure cash of 60 billion won and E.