법인세징수 및 부과처분 취소
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 August 19, 2014, C filed the instant lawsuit by the representative director deemed C as the custodian on the same day, as the Seoul Central District Court 2014 Ma10098, which was a company engaged in the manufacture, processing, and sale, etc. of electronic equipment, machinery, and apparatus, and their accessories.
On October 16, 2015, while the instant lawsuit was pending, C was changed to “A” on October 16, 2015. On the same day, “C” was newly established from “A” that was an existing company in accordance with the rehabilitation plan approved. On October 21, 2015, B and D were appointed as joint managers of “C” and taken over the instant litigation procedure.
In addition, C received major business assets, human resources, etc. of the existing company and received a decision to terminate rehabilitation procedures from the above court on November 26, 2015, and C took over the lawsuit of this case as the plaintiff.
(hereinafter referred to as “Plaintiffs”, including managers after the commencement of rehabilitation procedures. (b)
On December 21, 2006, the Plaintiff (hereinafter referred to as “E”) obtained re-permission of three U.S. registered patent rights, G (Korean Intellectual Property Office Registration Number H), I (U.S. Intellectual Property Office Registration Number H), and K (Korean Intellectual Property Office Registration Number L) (hereinafter referred to as “each of the instant patents”) from the U.S. registered patent rights from the U.S. Limited (hereinafter referred to as “F”), a corporation located in the Republic of Ireland (hereinafter referred to as “U.S.”) located in the Republic of Ireland (hereinafter referred to as “U.S.”) for the payment of the Plaintiff’s patent fees and withholding taxes. On April 22, 2010, the Plaintiff entered into a contract for re-permission of each of the instant patent rights between E and E on April 27, 2010, considered that the use fees of the Republic of Korea were 4,000,000 U.S. tax revenue owners and capital gains tax of the instant case.