종합소득세부과처분취소
1. The Defendant imposed global income tax of KRW 284,681,00 on Plaintiff A on August 1, 201.
1. Details of the disposition;
A. On September 21, 2004, Plaintiff A initially changed the Plaintiff’s trade name C from September 21, 2005 to N on September 21, 2005, and C again on April 20, 206.
(hereinafter referred to as “C”) was established, and Plaintiff A owned 3,00 shares out of 5,00 shares issued as representative director, and Plaintiff B, the wife of Plaintiff A, respectively, owned the remainder of 2,00 shares.
B. The Sejong Housing Co., Ltd. (hereinafter “Seoul Housing Co., Ltd.”) (hereinafter “Seoul Housing Co., Ltd.”) established a new apartment building on the Daegu-gu Seoul Special Metropolitan City D 1,641 square meters, E large 1,496 square meters, F large 117 square meters, G large 246 square meters, H large 95 square meters, and I large 4 square meters, and 3,599 square meters (hereinafter “project site”) in total, for the construction of a new apartment building, and multi-family housing was sold in lots, but a voluntary auction procedure (JJ of the Daegu District Court) for the project site was initiated due to bankruptcy.
C On March 21, 2005, the project site was sold at KRW 2.7 billion in the above voluntary auction procedure and completed the registration of ownership transfer on the 22th of the same month.
C. On August 26, 2005, the Plaintiffs entered into a pre-contract for the sale and purchase of the shares and bonds of M and C (hereinafter “instant shares and bonds”) on behalf of K and L (hereinafter “K”) and received KRW 100 million on the same day, and entered into a sales contract on September 6, 2005 (hereinafter “instant sales contract”), and received the down payment of KRW 900 million (including the advance payment) on the same day.
Article 2 (Certificate No. 15) The total amount of the objects to be traded under Article 2 of the Contracts for Transfer and Acquisition of Stocks and Bonds shall be 5.5 billion won.
Provided, That the claim for short-term loans held by Party A (Plaintiffs) against Party C is assessed as of the date of the contract and is included in the purchase price.
Section 3. At the same time as this contract is entered into, B (M acting on behalf of K, etc.) pays to A 1 billion won as down payment, etc., and the balance shall be paid immediately after the receipt of P.F. funds.
However, this contract does not pay any balance within three months after this contract.