증여세부과처분취소
1.The following dispositions shall be revoked:
As of August 25, 201, the director of the tax office of Samsung District Tax Office attached Form 1. 1.
A. The Plaintiff entered into a contract to transfer shares and management rights and exchanged shares on August 19, 2009 through public notice on July 9, 2009.
Accordingly, the corporation of this case changed to a specialized company that develops the stem cell therapy. D.
As a result of an investigation of stock change with respect to the pertinent corporation, the director of the Seoul Regional Tax Office: (a) deemed that the Plaintiff’s allocation of the instant shares constitutes donation of profits from capital increase under Article 39(1)1 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 9269, Jan. 1, 2010; (b) and notified the Defendants of taxation data.
The details of gift tax (unit: (1) the number of shares acquired by the plaintiff(s) and (2) the value of the gift tax per share after the increase of the capital; (2) the value of the property acquired by the plaintiff(s) [1] 】 (2) / (36,210 36,825* 16,200 891,206,250 17,147,040 [1] 16,864 636,580,000 112,250 - 250 per share after the increase of the capital; (3) the value of the shares acquired by the plaintiff(s) 2; (4) ; (2) ; (2) ; (3) ; (4) ; (4) ; (2) ; (3) ; (4) ; and (4) ; and (4) ; (2) ; (3) ; (4) ; and (4) ; (4) 2) ; (16) ; (6) ; (3) 2) ; and (3) 2) 4.