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(영문) 서울고등법원 2014.12.17 2014누52291

상속세부과처분취소

Text

1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

Reasons

1. The reasons why the court should explain by the court of first instance are as follows, except where the defendant adds a judgment of the first instance court, which is particularly emphasized or newly raised by the court, and thus, it is consistent with the reasoning of the judgment of the first instance. Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation

2. Judgment on the defendant's assertion

A. The Defendant’s assertion that it is difficult to believe transaction example among D and E is the same as that of the judgment of the court of first instance. D, who served as the representative director, appears to mean June 13, 201 as “stocks” as the expression of the parties. (5%) written a share transfer contract with the content that (145,00,000 won per share) was transferred from 145,000 won (96,666 won). However, unlike general cases, unlike the above share transfer and takeover contract, it is difficult to say that the share transfer and takeover contract forms the aggregate of three (1), (2) evidence No. 1, 6-1, 6-2, and (6) evidence No. 1 and 6-2 of the above share transfer and takeover contract amount are different from the transfer value per share transfer and takeover contract form, and the transfer value of No. 1,500,000 won and 16-1,000,000 won are different from the transfer value per share transfer and takeover.