법인세경정거부처분취소
1. The plaintiff's appeal and the plaintiff's claim expanded by this court are all dismissed.
2. The defendant's appeal.
1. On June 12, 2003, a national credit card company (hereinafter “national credit card company”) established the National Card No. 16 Limited Company (hereinafter “16 Limited Company”) and sold the credit card bonds of KRW 135 billion to the 16th limited company (hereinafter “16th limited company”), and the 16th limited company decided to grant credit to the securitization bonds issued by the 16th limited company by using the above card bonds as basic assets.
On September 5, 2003, the national credit card established a limited liability company specializing in the national credit card system (hereinafter "the 17th limited liability company") and the 16th and 17th limited liability companies together with the 17th limited liability companies (hereinafter "the 17th limited liability companies") and sold 54 billion won credit card bonds to the 17th limited liability companies (hereinafter "the 17th securitization transfer contract"; the 16th and 17th securitization transfer contract collectively referred to as "the transfer contract of the securitization assets"); and the 17th limited liability companies decided to grant credit to the securitization bonds issued by the 17th limited liability companies with the above card bonds as the basic assets.
(B) The Plaintiff, upon the request of the instant limited liability company from October 1, 2003 to March 2004, acquired 33,295 card bonds (41,982,819,261 won) from the 16th limited liability company, and 161,647 card bonds (38,220,959,002 won) from the 17th limited liability company.
(2) The Plaintiff purchased credit cards from the instant limited liability company (hereinafter referred to as “the instant credit card claim”) from the instant limited liability company, and paid for the acquisition of credit cards (hereinafter referred to as “the instant payment”). Since April 2004, the Plaintiff purchased credit cards from the instant limited liability company several times, and lent money to the instant limited liability company (credit extension).