종합소득세부과처분취소
1. The Defendant’s global income tax of KRW 9,134,401,80 on April 11, 2014, as global income tax of KRW 1,473,493,306;
1. The Inspector B Co., Ltd. (hereinafter “B”) operates E in the D hotel located in Seopo City of Jeju Special Self-Governing Province (hereinafter “B”).
The Busan Regional Tax Office conducted a tax investigation on B from November 8, 2012 to July 31, 2013, and then notified the Defendant of the result of the tax investigation on the sales amount of 2011 to KRW 31.1 billion, on the ground that the ownership of the difference between the sales amount reported in the business year 2011 is unclear.
The Defendant: (a) deemed the portion of the business year to which 22,216,290,320 won reverts (hereinafter “instant income”); and (b) notified the change in the amount of income to the Plaintiff on April 11, 2014, the Defendant imposed global income tax of KRW 9,134,401,80 (including additional tax of KRW 1,473,493,493,306, additional tax of KRW 293,941,964) on the said income on the Plaintiff on April 11, 2014.
(hereinafter “Disposition in this case”). / [Grounds for recognition] without dispute, entry of Gap evidence No. 1, and purport of the whole pleadings
2. Whether the instant disposition is lawful
A. 1) The gold Industry Development Co., Ltd. (hereinafter referred to as “the gold industry development”).
(B) 100% (ordinary share 30,000 shares) of the shares issued B were issued.
(2) The shares were owned by the Busan Savings Bank. (4) The shares were held by the Busan Savings Bank. (4)
() On December 15, 2010, the Plaintiff agreed to transfer all of B’s shares 100%, E business license, and assets in the E business place to the Plaintiff at KRW 14.6 billion. The Plaintiff paid the down payment of KRW 1 billion on the date of the contract, and the remainder of the down payment and the intermediate payment of KRW 1.3 billion until December 24, 2010, and the remainder of KRW 12.3 billion until January 15, 201 (the gold amount was paid by the Plaintiff when the industrial development issues a certificate of delivery of shares).
. The gold Industry Development will be ordered to obtain from the Busan Savings Bank a certificate to the effect that if the remaining loans are repaid at the time of the contract, the outstanding pledge will be cancelled and the share certificates will be returned.