법인세부과처분등취소
1.(a)
The corporate tax for the business year 2002 against the Plaintiff on July 12, 2010 is the additional tax of KRW 4,392,097,510.
1. Details of the disposition;
A. (1) The Plaintiff is a corporation established on November 15, 1930 and engaged in cargo transport, cargo loading and unloading, container terminal business, warehouse business, etc.
(2) From May 199 to June 30, 2005, C served as the Plaintiff’s representative director or legal administrator.
D served as the head of Busan branch office from November 200 to June 30, 2005, and as the representative director or legal administrator from July 1, 2005 to 2010.
B. From March 2, 2010 to June 30, 2010, the head of the Seoul Regional Tax Office determined that the Defendant released the company fund by investigating the Plaintiff’s tax offense, and by including the Nonindicted Fund KRW 32,140,675,936 (hereinafter “Nonindicted Fund”) created by using false simple receipts, etc. from 2001 to 2007 in deductible expenses, and reporting corporate tax to the deductible expenses.”
The director of the Seoul Regional Tax Office, who was the representative director of the Plaintiff, disposed of the funds of this case as bonus for C and D, on July 8, 2010, notified the Plaintiff of the change in the amount of income as stated in the column of “the initial income” in the attached Form of notice of change in the amount of income, and notified the Defendant Southern District Tax Office of taxation data.
C. Accordingly, on July 12, 2010, the director of the tax office of South Korea excluded the foreign capital from deductible expenses, and notified the Plaintiff of the rectification of corporate tax for the business year from 2002 to 2005 as follows.
(hereinafter "Imposition of Corporate Tax"). (The imposition of additional tax for the business year of this case shall be 20022,093,605,605,4208, 742, 678, 605, 627, 627, 947, 991,666, 779, 749, 764, 3042, 298, 492, 052, 397, 5039, 2374, 2397, 478, 478, 478, 652, 742, 682, 648, 94, 94, 942, 2942, 294, 198, 294, 205, 294, 3194, 294, 2054, 2947
D. (1) The Plaintiff appealed and filed an appeal on October 5, 2010, and on September 4, 2012.