종합소득세부과처분취소
1. The defendant's appeal is dismissed.
2. The defendant bears the total costs of the lawsuit after the filing of the appeal.
purport, purport, and.
Details of the disposition
On July 29, 201, the Defendant: (a) lent KRW 160,00,000 to B; (b) received reimbursement of KRW 708,542,031 (i.e., KRW 708,542,542,031 (i.e., KRW 708,542,031 - KRW 160,000,000; hereinafter “instant income”); and (c) received interest income of KRW 548,52,031 (i.e., the instant income”); and (d) issued a disposition imposing global income tax of KRW 225,121,350 (hereinafter “instant disposition”).
After that, the Defendant changed the reason for disposition by the court prior to the remanding of the case, that the income of this case constitutes the dividend income under Article 17 (1) 9 of the Income Tax Act (the income similar to the income under subparagraphs 1 through 7 of the same Article, which has the nature of profit distribution) as the “income equivalent to the amount that is the value of the money and other property acquired by the investor due to the withdrawal exceeds the amount required by the investor to acquire the investment” under Article 17 (1) 3 and (2) 1 of the Income Tax Act, which was received as a distribution of profits by the Plaintiff from the partnership partnership B
(1) The Plaintiff’s global income tax amount for the year 209 after the modification is identical to the disposition tax amount of this case, even if the cause of the disposition of this case is changed, the Plaintiff’s global income tax amount for the year 2009 after the modification is identical to the disposition tax amount of this case). [In the absence of dispute, the entry of No. 1, No. 1, and No. 1, and the purport of the entire pleadings, and the Plaintiff’s investment of KRW 160,000 in total to B, who was in the relationship with the Plaintiff, without any specific consideration agreement, in light of the purport of the disposition of this case as a whole, as it constitutes global income subject to cumulative taxation under the Income Tax Act. The Plaintiff’s investment of KRW 160,000,000,000 in total, without any specific consideration agreement, was made to the Plaintiff.