수년간 반복적으로 가공원가를 허위로 계상한 행위는 부당과소신고가산세 적용대상임[국승]
Seoul Administrative Court 2015Guhap61269 ( November 27, 2015)
Conducts for which a false park has been repeatedly appropriated for several years shall be subject to the application of an unfair underreporting penalty tax.
The act of repeatedly calculating a false park for several years constitutes an active act such as making it difficult to detect the taxation requirement by making it difficult to discover the fact or forging false facts by means of false entry in the book, or by manipulating or concealing income, profits, acts and transactions.
2015Nu72896 Revocation of Disposition of Imposing global income tax, etc.
OO et al. 1
O Head of tax office
Seoul Administrative Court Decision 2015Guhap61269 decided November 27, 2015
July 6, 2016
July 20, 2016
1. All appeals filed by the plaintiffs are dismissed.
2. Of the appeal costs, the part arising between the Plaintiff’s OO and the Defendant’s Samsung Head of the tax office is borne by the Plaintiff’s OO, and the part arising between the Plaintiff’s BigOOOO and the Defendant AA Head of the tax office is borne by the Plaintiff’s BigOOO.
The judgment of the first instance court is revoked. The imposition of O, O,O,O, andOO on April 15, 2014 by the head of the defendant's OOO head of the tax office on global income tax for the year 2008 is revoked, respectively. The imposition of O, O,O, andOO for an unfair under-reported additional tax on global income tax for the year 209 is revoked. The imposition is revoked by the head of the defendant AOO head of the tax office on April 14, 2014 against the plaintiff corporation POOOO(hereinafter referred to as "the plaintiff corporation") on the plaintiff corporation POOO(hereinafter referred to as "the plaintiff corporation") on the corporate tax for the year 2009, each of the imposition of an under-reported additional tax on under-reported under-reported under-reported under-reported under-reported under-reported under-reported tax for the corporate tax for the business year 2010.
1. Quotation of judgment of the first instance;
The reasoning of this court's judgment is the same as that of the court of first instance, and thus, it is cited in accordance with Article 8 (2) of the Administrative Litigation Act and Article 420 of the Civil Procedure
2. Conclusion
The judgment of the first instance is justifiable. All appeals filed by the plaintiffs are dismissed.