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(영문) 서울고등법원 2011. 06. 09. 선고 2010누40375 판결

우회양도의 경우 양도소득세 부당행위계산부인[국승]

Case Number of the immediately preceding lawsuit

Suwon District Court 2010Guhap7278 (Law No. 29, 2010)

Case Number of the previous trial

The early appellate court 2010 middle 3583

Title

In the case of a transfer bypass, the wrongful calculation division

Summary

(The same as the judgment of the first instance court) In the case of a bypass transfer, only the cases where objective circumstances exist, such as unreasonably reducing taxes, etc., when the sum of the gift tax and the capital gains tax to be borne by the donee is smaller than the income tax

Cases

2010Nu40375 Revocation of Disposition of Imposing capital gains tax

Plaintiff and appellant

XX Kim

Defendant, Appellant

O Head of tax office

Judgment of the first instance court

Suwon District Court Decision 2010Guhap7278 Decided September 29, 2010

Conclusion of Pleadings

April 14, 2011

Imposition of Judgment

June 9, 2011

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 judgment of the first instance shall be revoked. The imposition of capital gains tax of KRW 271,376,750 against the plaintiff on May 14, 2009 by the defendant shall be revoked.

Reasons

1. Quotation of judgment of the first instance;

The reasoning for the court's explanation on this case is as follows: "Gift 405,7709 won" in Part 5 of the judgment of the court of first instance shall be "Gift 405,770 won"; and "related Acts and subordinate statutes" in the attached Form shall be as stated in the reasoning of the judgment of the court of first instance, except for the case where "Gift 405,770 won" shall be "Gift 405,770 won"; therefore, it shall be cited as it is in accordance with Article

2. Conclusion

Therefore, the plaintiff's claim of this case is dismissed as it is without merit, and the judgment of the court of first instance is just, and the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.