종합소득세부과처분취소
1. Of the instant lawsuit, the part of the claim for revocation of the disposition imposing global income tax for the year 2009 is dismissed.
2. The plaintiff.
1. Details of the disposition;
A. From 2009 to 2012, the Plaintiff purchased 19 real estate collateral bonds from Solomon Savings Bank, etc. (hereinafter “instant bonds”) and received dividends or repayment from the debtor in the auction procedure for secured real estate (hereinafter “instant income activities”), thereby gaining gains from the gains of KRW 6,367,53,972 in total (hereinafter “instant income”). < Amended by Act No. 449,878,866, Jun. 34, 2010; Act No. 634,083,619, 4,016,088,729,729, and KRW 1,267,502,758 in total (hereinafter “instant income”).
B. On June 1, 2014, the Defendant: (a) deemed that the instant income constituted business income under Article 19(1)20 of the Income Tax Act; and (b) determined and notified each of the total income tax of KRW 213,337,360 for the year 2009; (c) KRW 129,004,420 for the year 2010; (d) KRW 1,783,591,460 for the year 201; and (e) KRW 406,567,150 for the year 201.
(hereinafter referred to as “the first disposition”). (c)
On July 11, 2014, the Plaintiff filed an appeal with the Tax Tribunal for adjudication, and on December 9, 2014, “the initial disposition at issue” means that the amount of dividend shall be the revenue amount, and the acquisition value of non-performing loans shall be included in purchase expenses, and the tax base and tax amount shall be corrected by estimation, and the remainder of the appeal shall be dismissed.
‘The decision was made'. D.
According to the above decision, the Defendant issued a correction and notification of reduction as stated in the original disposition’s claim on December 24, 2015, as the amount of each global income tax accrued from 2009 to 2012.
hereinafter referred to as "disposition of this case"
(ii) [Grounds for recognition] unsatisfy, Gap evidence 1 to 3 (if any, with a tentative number);
hereinafter the same shall apply.
written evidence Nos. 1 and 2 and the purport of the whole pleadings
2. To make entries in the attached statutes concerned;
3. On January 29, 2016, the disposition of imposition of global income tax of KRW 213,177,691 as global income tax for the year 2009, among the instant lawsuit, was lawful, was completely reduced.