(심리불속행)이 사건 세무조사는 국세기본법 제81조의4 제2항 제1호에 따라 예외적으로 허용되는 재조사임[국패]
Seoul High Court-2016-Nu-7909 (Law No. 19, 2018)
Cho Jae-2015-Seoul Government-539 (24 March 2016)
(Re-investigation) The investigation of this case is exceptionally permitted pursuant to Article 81-4(2)1 of the Framework Act on National Taxes.
(2) The tax authority should prove that the amount of the instant tax investigation is interest on the non-business loan, which is exceptionally permitted pursuant to Article 81-4(2)1 of the Framework Act on National Taxes. Therefore, it is difficult to conclude that the instant amount is interest income.
2018du44500 Global income and revocation of disposition
AA
a) the Director of the Tax Office
Seoul High Court Decision 2016Nu79009 Decided April 19, 2018
September 5, 2018
The appeal is dismissed.
The costs of appeal are assessed against the defendant.
Examining the judgment below and the grounds of appeal, since it is apparent that the appellant’s ground of appeal falls under Article 4 of the Act on Special Cases Concerning the Procedure for Appeal, the appeal is dismissed under Article 5 of the above Act. It is so decided as per Disposition by the assent of all participating Justices.