이 사건 조합의 조합원에게 선수토지사용료가 귀속되어 종합소득세 납세의무가 있는지 여부[국승]
Seoul Administrative Court-2017-Gu Partnership-76159 (2018.06.01)
Whether a partner of the instant association is liable to pay global income tax due to the ownership of the player land usage fee.
(As in the first instance judgment, the association is liable to pay income tax depending on the income distributed to each joint proprietor of the business as the method of distributing the profits or the ratio of distributing the profits to its members are determined and actually distributed to the non-corporate entity.
Article 13 of the Framework Act on National Taxes, Article 2 of the Income Tax Act
Seoul High Court 2018Nu52206 Global Income and Revocation of Disposition
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AA Head of the Tax Office
January 16, 2019
January 30, 2019
1. The plaintiff's appeal is dismissed.
2. The costs of appeal shall be borne by the Plaintiff.
The judgment of the first instance shall be revoked. The defendant's imposition of global income tax (including additional duties) for the plaintiff and the imposition of global income tax for the plaintiff and the imposition of global income tax for the plaintiff shall be revoked.
1. Quotation of judgment of the first instance;
The reason why this Court is to use for this case is as stated in the reasoning of the judgment of the court of first instance.
It shall be quoted in accordance with Article 8 (2) of the Transmission Act and the main sentence of Article 420 of the Civil Procedure Act.
2. Conclusion
Thus, the plaintiff's claim of this case shall be dismissed as it is without merit, and the judgment of the court of first instance shall be this.
As a result, the plaintiff's appeal is dismissed.