(심리불속행) 특허권 대여 행위의 영리성, 반복성 등을 볼 때 사업소득으로 과세한 당초 처분은 적법함[국승]
Seoul High Court 2012Nu19726 ( December 07, 2012)
early 201J 0289 ( October 30, 2011)
(C) The initial disposition that was imposed as business income is legitimate in light of the nature of profit-making, repetition, etc. of patent lending.
In light of social norms, the initial disposition imposed as business income in light of various circumstances, such as the commercial nature of patent lending, the existence of continuous and repeatedness, the length of the transaction period, and the amount provided.
2013du1836 global income and revocation of disposition
UnionA
Head of Sungnam Tax Office
Seoul High Court Decision 2012Nu19726 Decided December 7, 2012
The appeal is dismissed.
The costs of appeal are assessed against the Plaintiff.
All of the records of this case, the judgment of the court below, and the grounds of appeal by appellant are examined, and it is clear that the grounds of appeal fall under Article 4 of the Act on Special Cases Concerning the Procedure for Appeal, and the appeal is dismissed under Article 5 of the same Act. It is so decided as per Disposition by
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