종합소득세부과처분취소
1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. From September 7, 2006 to May 28, 2007, the mid-term regional tax office: (a) conducted a special tax investigation with respect to B and C corporation operated by B as the representative director; and (b) sent the assessment data on gift tax to the head of Seocheon District Tax Office by deeming B as evading gift tax. Accordingly, the head of Seocheon District Tax Office imposed a gift tax amount of KRW 1,354,836,550 on B with respect to the gift bypass on June 20, 207; and (b) imposed a gift tax of KRW 6,363,53,570 with respect to the dividend of the corporation on November 15, 207 (hereinafter collectively referred to as the “assessment disposition on gift tax of this case”); and (c) imposed a gift tax of KRW 1,354,836,53,570 with respect to the dividend of the corporation ( collectively referred to as “the imposition disposition on gift tax of this case”).
(2) From January 1, 200, the Plaintiff had a tax accountant operating the “A Tax Accounting Office” in Gangnam-gu Seoul Metropolitan Government, and on December 10, 2007, the Plaintiff was delegated by B’s agent E to object to the disposition of gift tax imposition (hereinafter “instant delegation contract”), and written a contract with the following contents (hereinafter “instant delegation contract”).
The agent contract for appeal (A) : B : The purpose of this contract is to delegate the authority of the A to the B to act as an agent with respect to the filing of objections, requests for examination, requests for adjudication, and requests for examination by the Board of Audit and Inspection (hereinafter referred to as "request for appeal") with respect to the following cases.
(1) Case name: (2) : summary of case of cancelling gift tax - (2): - Tax agency: Gift tax - Amount of notified tax - Amount of tax: Amount of tax by the head of Seocheoncheon District Tax Office - amount of tax of KRW 1,354,836,550: case 2, “6,363,553,570” - Date of notice notice: June 20, 2007; remuneration for business entrusted by Article 5 (Remuneration) on November 15, 207 shall be refunded (including interest on refund) or cancelled by appeal as prescribed in Article 1; and 20% of the amount of remuneration by adding the amount of remuneration.