세무조사결정처분취소
1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. The Plaintiff Company was established on December 2, 1981 and thereafter constituted a limited partnership company, a general partner B, a limited partner C, a limited partner D, and E, which is a representative member from around that time.
B. F is an employee who served as a vice president in the Plaintiff Company for about 10 years. From September 2014, 2014, F is the Defendant’s “documents of “the gas purchase volume, sales volume, and surplus amount, and entries in the present status of surplus amount” (hereinafter “the instant information materials”) to the Defendant.
(1) The investigation period from January 1, 2009 to December 31, 2013: the investigation period: the investigation period from September 24, 2014 to October 31, 2014: the investigation period is from September 24, 2014; it is analyzed that there is an omission of the amount of income, etc.; and it is selected as a person subject to investigation to verify the propriety of the report (Article 81-6(3) of the Framework Act on National Taxes).
C. On the basis of the instant information data, etc., the Defendant deemed that there was a suspicion that the Plaintiff Company was under suspicion of omitting a sales report by means of adjusting the reported sales amount from 2009 to 2013 in comparison with the actual sales amount, and pursuant to Article 81-6(3) of the Framework Act on National Taxes, pursuant to Article 81-6(3) of the Framework Act on National Taxes, the Defendant selected the Plaintiff Company as a person subject to investigation and notified the Plaintiff Company thereof. The notification was served on the Plaintiff Company on September 26,
On November 20, 2014, the Plaintiff Company filed a petition with the Tax Tribunal for a trial on November 20, 2014. However, on August 27, 2015, the Tax Tribunal rendered a decision of rejection on the ground that the decision of tax investigation cannot be deemed a disposition subject to a request for a trial, and the decision was served on the Plaintiff Company on August 31, 2015.
[Ground of recognition] Facts without dispute, Gap evidence 5, Gap evidence 6-1, 2, Gap evidence 18-1, Eul evidence 2, the purport of the whole pleadings
2. The defendant's judgment on the main defense of the safety.