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(영문) 서울고등법원 2017.06.29 2016누48012

법인세부과처분취소

Text

1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

The first instance court.

Reasons

1. The reasoning of the judgment of the court of first instance is as follows, and it is identical to the reasoning of the judgment of the court of first instance, except for adding some contents and adding some contents. As such, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

The first instance court's 6th decision in the first instance court's 7th decision in the first instance court's 7th decision is as follows.

【This result of the Plaintiff’s repayment of, or non-existence of, borrowed money that does not exist in AF, etc. who is a specially related corporation D, which resulted in the same effect as an anti-restricted act. 【The Plaintiff’s repayment of, or non-existence of, borrowed money that is not a specially related corporation AF, etc.】 The following is added in

2) On January 201, 201, the Plaintiff bears the obligation to pay KRW 3 billion for sales agency fees to AV, which performed the sales agency of AU hotel located at the Seocho-si. However, AV purchased the name golf membership in the Plaintiff’s issuance through the member exchange, and subsequently sold the terms and conditions of the benefits of the Plaintiff’s membership to the higher price than the right of the non-member, thereby exempting the Plaintiff from the obligation to pay the sales agency fees.

A person shall be appointed.

2. The judgment of the first instance court is justifiable, and the plaintiff's appeal is dismissed as it is without merit.