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(영문) 서울고등법원 2016. 09. 22. 선고 2016누38930 판결

이 사건 주택은 양도소득세 비과세대상에서 제외되는 고급주택에 해당하고, 고급주택여부는 ‘양도 당시의 실지거래가액’을 기준으로 판단하여야 함[국승]

Case Number of the immediately preceding lawsuit

Suwon District Court-2015-Gudan-701 ( October 17, 2016)

Case Number of the previous trial

Cho Jae-2014-1394 ( December 11, 2014)

Title

The instant house constitutes a high-class house excluded from capital gains tax exemption, and the high-class house should be determined based on the actual transaction price at the time of transfer.

Summary

(1) Since the instant house constitutes a high-class house, it is reasonable to view that the instant house is excluded from the capital gains tax reduction or exemption pursuant to the proviso of Article 99-3 (1) of the former Restriction of Special Taxation Act, and whether it constitutes a high-class house should be determined based on the actual transaction price at the time of transfer.

Related statutes

Article 99-3 of the Restriction of Special Taxation Act (Special Taxation for Capital Gains Tax for Purchasers of Newly-Built Houses)

Cases

2016-Nu-38930 Revocation of Disposition of Imposing capital gains tax

Plaintiff and appellant

AA

Defendant, Appellant

o Head of the tax office

Judgment of the first instance court

Suwon District Court Decision 2015Gudan701 Decided October 17, 2016

Conclusion of Pleadings

July 14, 2016

Imposition of Judgment

September 22, 2016

Text

1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

The judgment of the first instance shall be revoked. The defendant shall revoke the disposition rejecting a request for correction of capital gains tax against the plaintiff on September 23, 2013.

Reasons

1. Quotation of judgment of the first instance;

The reasoning of this court's decision is as follows: Article 8 (2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act, except where "the housing of this case" in Part 6, 19 of the judgment of the court of first instance is referred to as "the housing of this case" as "the housing of this case".

2. Conclusion

Since the judgment of the first instance is justifiable, the plaintiff's appeal is dismissed as it is groundless.