제반 사실관계 고려시 피고가 경정한 매도자 양도가액이 원고(매도자)가 신고한 양도가액보다 타당함[국승]
Seoul Administrative Court-2014-Gu Group-59 ( October 29, 2014)
Cho Jae-2013-west-472 (1.03, 2014)
In consideration of all the facts, the transfer value of the seller corrected by the defendant is more reasonable than the transfer value reported by the plaintiff (seller).
(1) As to the correction of the difference between the transfer value of the seller (the same as the judgment of the first instance) and the transfer value of the purchaser, the previous and previous facts of the Plaintiff’s reported transfer value and the Plaintiff’s transfer value corrected by the tax authorities are examined, and the adjusted transfer value by the
Article 114 of the Income Tax Act (Determination, Revision and Notification of Tax Base for Transfer Income and Amount of Tax)
Seoul High Court-2014-Nu-6388 ( October 08, 2015)
2014Nu6388 Revocation of Disposition of Imposing capital gains tax
Park*
*The Director of the Tax Office
on October 2015 08
United States, U.S., U.S.C.
Park*
*The Director of the Tax Office
Seoul Administrative Court Decision 2014Gudan51459 decided October 29, 2014
The plaintiff's appeal is dismissed.
Expenses for appeal shall be borne by the plaintiff.
1. Quotation of judgment of the first instance;
The reasoning for this court's reasoning is as follows: (a) the first instance court's judgment was sold to ○○○○ because it sold 'the second instance court' ***** in the second instance court's judgment 'the sales of 'the second instance court' to 'the second instance court' ** in the transfer amount by succeeding the payment obligation of *** in the transfer amount by succeeding the payment obligation of ○○○○○○; and (b) the second instance court's judgment is the same as the entry of the judgment of the first instance court except for adding the judgment on the plaintiff's justifiable argument under Article 8 (2) of
2. Judgment on the plaintiff's assertion of the trial
In the trial of the party, the plaintiff alleged that the plaintiff sold the right to sell this case to new ○○○,** the balance of the redevelopment association ****0,000 won and received KRW 200,000,000 from new ○○○, and that there was no additional KRW *,000,000 from new ○○○ side, which correspond to the plaintiff's argument. He asserted that the testimony ** is difficult to believe it in light of the entries in No. 1, 2, 6, and 8 of No. 1-2 of the evidence No. 1-2, and the fact-finding results of each fact-finding on the national bank of the court of the first instance, which corresponds to the plaintiff's argument, in consideration of the entries in No. 5 of the evidence No. 1-2, 6, and 8 of
3. Conclusion
Therefore, the judgment of the first instance court is legitimate, and the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.