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(영문) 서울고등법원 2018.04.18 2017누76182

증여세부과처분취소

Text

1. Revocation of a judgment of the first instance;

2. As to the Plaintiff A and B, the head of the Dong Dong District Tax Office is the director of the Dong Dong District Tax Office.

Reasons

1. The grounds for this part of the disposition by the court are the same as the corresponding part of the judgment of the court of first instance (from No. 2 to No. 45). Thus, the grounds for this part of the disposition are cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

(hereinafter the meaning of the abbreviationd language used in this case is the same as the judgment of the first instance). 2. Whether each disposition of this case is lawful

A. The grounds for this part of the plaintiffs' assertion are as stated in the corresponding part of the judgment of the court of first instance (from 4th to 8th 5th eth eth eth eth eth eth eth eth eth eth eth eth eth eth e)

[However, "(title trust 1)" shall be added after the last day of the fourth 19th and the fifth 7-9 main part shall be deleted.]

The attached details of the relevant statutes shall be as specified in the statutes.

C. Determination 1) As to the absence of a title trust agreement, Article 41-2(1) of the former Inheritance and Gift Tax Act and Article 45-2(1) of the former Inheritance and Gift Tax Act apply in cases where the actual owner and the nominal owner register in the future under an agreement or communication with respect to the property requiring the transfer or exercise of the right, etc., in which the title holder and the nominal owner register in the future, the registration under the nominal owner is unilaterally made. In this case, if the tax authority proves that the actual owner is different from the nominal owner, the certificate that the registration, etc. in the nominal owner was made in the unilateral act of the actual owner regardless of the intent of the nominal owner should be by the nominal owner

(see, e.g., Supreme Court Decision 2007Du15780, Feb. 14, 2008) The following facts are either a dispute between the parties or acknowledged based on Gap evidence Nos. 2, 4 through 23, and 25 (where a serial number exists, each entry including a serial number, and witness N of the first instance trial and P’s testimony.

(1)