상속.증여세경정청구부과처분취소
1. The plaintiffs' claims are dismissed.
2. The costs of lawsuit are assessed against the plaintiffs.
1. Details of the disposition;
A. (1) The assessment of inheritance tax and gift tax (1) died on August 6, 2008, and D returned and paid 391,227,890 won of inheritance tax on December 8, 2008 by the wife who is the inheritor, Plaintiff B, Plaintiff A, C, E, and F as KRW 9,098,719,837.
The Seoul Regional Tax Office conducted an additional tax investigation on October 12, 2009 and donated the listed shares of the Mo Securities Account (hereinafter “instant shares”) managed under the names of the Plaintiffs and E on July 26, 2007, as follows: (a) Hyundai Securities J 959,151,843, 2,42,983,014 (2) Hyundai Securities J 293,707,730 E; (b) Hyundai Securities J 959,151,843, 2,442, 983,014 (2).
For reasons, “The gift tax due to prior donation 791,796,792 won, inheritance tax 1,204,965,602 won shall be imposed.”
"The results of the tax investigation were notified."
(3) The Plaintiffs and E filed a request for pre-assessment review on November 11, 2009, but received a non-adopted decision from the Seoul Regional Tax Office on January 29, 2010.
(4) (A) On February 10, 2010, the director of the Seoul Regional Tax Office notified the Defendants of taxation data, and on February 10, 2010, the director of the Seoul Mapo District Tax Office notified the Plaintiff A of KRW 324,057,140 (including additional taxes), the director of the Seoul District Tax Office notified the Plaintiff of KRW 101,702,340 (including additional taxes) gift tax, and the director of the Seoul Samsung District Tax Office notified the Plaintiff C of KRW 70,160,240 (including additional taxes) of gift tax.
(B) In addition, on June 8, 2008, the Defendants notified the Plaintiffs of the correction of KRW 1,225,520,850 (including additional tax) by adding the value of the instant shares to the taxable value of inherited property.
B. F’s filing of the suit and compulsory conciliation(1) F against the Plaintiff A and K Co., Ltd. (the Plaintiff was the representative director of the Plaintiff; hereinafter “K”) in Seoul Western District Court (2008Gahap8904) for ownership transfer registration and the claim for issuance of shares.