종합부동산세등부과처분취소
1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. On January 22, 2008, Songin FV purchased a total of 12 parcels of land in Pyeongtaek-si B from A, a total of 13 parcels of land in the same Dong from C, and a total of 5 parcels of land in the same Dong from D, respectively, on August 24, 2009, Songin FV paid the sales price in full to A, C, and D on August 24, 2009, but did not complete the registration of ownership transfer by June 1, 201, which is the global real estate holding tax base date for the year 2011.
3) On November 16, 2011, the Defendant: (a) deemed that Songinindo had de facto owned a total of 28 parcels of land among each of the lands listed in paragraph (1) as at the tax base date; and (b) designated Songindo as at December 15, 201 the due date for payment as at December 15, 201 and imposed a disposition of KRW 329,295,855,850 of the comprehensive real estate holding tax for year 201 and the special rural development tax for which it is principal tax.
(hereinafter “PFV’s respective tax liability” (hereinafter “principal tax liability”) and on the other hand, on June 1, 201, the date when the consignor’s primary tax liability becomes effective, the Daewoo Motor Sales Co., Ltd. (hereinafter “PFV sales prior to division”) (hereinafter “PFV sales”).
) 80.46% of the shares issued by Songinin-V (hereinafter “instant shares”)
B. (B) On August 10, 201, the company division of the Daewoo Motor Sales and the Plaintiff’s establishment following such division were owned. However, on August 10, 201, the Daewoo Motor Sales was decided to commence the rehabilitation procedure (hereinafter “instant rehabilitation procedure”) under the Debtor Rehabilitation and Bankruptcy Act (hereinafter “ Debtor Rehabilitation Act”) by Seoul Central District Court 2011 Gohap105.
2) Under the instant rehabilitation procedure, the rehabilitation plan submitted by the administrator of the treatment Motor Vehicle Sales prior to the split-off on December 9, 201 was approved (hereinafter the above approved rehabilitation plan is referred to as “instant rehabilitation plan”).
3) The instant rehabilitation plan is prior to the division.