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(영문) 서울행정법원 2015.02.05 2014구합67864

법인세경정및소득금액변동통지처분의취소청구

Text

1. All of the plaintiff's claims are dismissed.

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

Reasons

1. Details of the disposition;

A. The Plaintiff is a company established on October 23, 1954 and engaged in real estate rental business in Jongno-gu Seoul Metropolitan Government, and the Plaintiff’s shareholder composition is as listed below.

Table 1 (Unit: 70,500 5,500 5,250,000 4.063 4.063 500 5,500 36,250,000 50 36,250,000 4.312 5,400 50 1,700 3,700 500 1,700 500 1,700 125 3,400 501,70 500 500 1,700,000 125 3,400 50 1,700 50 1,700 50 3,400 1,400 125, 1200 100 1,50 100 10,50 10,50 10

B. The Plaintiff: (a) lent funds to F and stockholders C, D, and E (hereinafter “specially related persons”) without any connection with their business affairs; (b) calculated the interest accrued from the end of each business year as the revenue amount; and (c) calculated the interest accrued therefrom as the revenue amount; and (d) continued to account the interest accrued at the end of the following business year (the first day of the following business year from April 1, 2012 to March 31, 2013) after one year from the date the interest accrued; (b) calculated the tax base amount of each business year and the tax amount on the basis thereof, and reported and paid the amount of the tax base amount of each business year and the tax amount on the basis thereof. From April 1, 2008 to March 31, 2019 to April 1, 2013 (hereinafter “instant business year”); and (c) calculated the interest accrued therefrom as the income amount and the calculation of the income accrued during the business year from March 31, 2012.

Table 2. [Attachment 3.3. 4. 4. 4. 1. 4. 4. 4. 4. 1. 6. 3. 3. 4. 4. 18, 5728, 2824. 3. 4. 3. 1. 3. 4. 3. 4. 1. 4. 5, 5728, 575 4, 575 7. 7. 4. 1. 4. 5. 1. 1. 3. 4. 1. 4. 1. 4. 5, 1. 1. 1. 385, 926, 401 . 4. 2. 4. 3. 1. 5, 1. 3. 1. 8. 1. 4, 2. 1. 8. 4. 1. 5, 2008