증여세부과처분취소
1. All appeals by the defendant against the plaintiffs are dismissed.
2. The costs of appeal shall be borne by the Defendant.
purport, purport, and.
1. Details of the disposition;
A. Since its incorporation on July 31, 2003, E Co., Ltd. (hereinafter “instant company”) was a company that engaged in road packaging business, etc. in the same city F, Andong-si. The Plaintiffs are those who are in office as an internal director or auditor of the instant company.
On the other hand, both plaintiffs B, C, and D are siblingss of G, and plaintiffs A are children of G.
B. From October 31, 2013 to November 27, 2013, the commissioner of the Daegu Regional Tax Office investigated whether the instant company was subject to the change of shares, and notified the Defendant of the imposition of gift tax by deeming that the instant company’s shares acquired by Plaintiff B, C, and D were owned by Plaintiff B, C, and December 10, 2005, and 14,500 shares of the instant company acquired by Plaintiff A (hereinafter collectively referred to as “instant shares”) of October 28, 2010, for the purpose of evading G tax, with the intention of evading G tax.
C. Accordingly, the Defendant rendered a separate decision and notification (including additional tax) as follows to the Plaintiffs (hereinafter collectively referred to as “instant disposition”) on the number of shares on the date of acquisition on September 13, 2003 B, and the amount of taxation on the date of disposal (won) as follows: 37,032,00 C on September 13, 2003; 50 on October 13, 2014; 37,032,000; 52,102,750 on 10, 204. 31, 50, 508; 40. 1, 208; 10. 4, 208; 10. 5, 200; 10,624, 030 on February 1, 2014; 10, 2014;
The Plaintiffs filed an objection against the instant disposition on April 9, 2014, but the Superintendent of the Daegu Regional Tax Office decided to dismiss it on May 23, 2014, and the Plaintiffs filed an appeal with the Tax Tribunal on August 22, 2014, but the Tax Tribunal dismissed it on December 30, 2014.
[Ground of recognition] Facts without dispute, Gap evidence 1 through 3 (including each number, hereinafter the same shall apply), Eul evidence 1, 2, 4, and 6, and the purport of the whole pleadings
2. Whether the instant disposition is lawful.