원고는 법인세법 제52조에서 규정하는 특수관계자에 해당함.[국승]
Daegu District Court-2014-Gu Partnership-20799 ( October 15, 2014)
The plaintiff constitutes a specially related person under Article 52 of the Corporate Tax Act.
The plaintiff is a person who is recognized as exercising de facto influence over the management of the corporation, such as exercising the right to appoint officers or determining the business policy, and falls under a specially related person.
Article 52 of the Corporate Tax Act
Daegu High Court-2014-Nu-624 ( October 16, 2015)
UnionA
Head of Dong Daegu Tax Office
Daegu District Court-2014-Gu Partnership-20799 ( October 15, 2014)
2015.994
oly 15, 2015
1. Quotation of judgment of the first instance;
The reasons why the court should explain the instant case are partially dismissed or added as follows.
Inasmuch as the reasoning of the judgment of the court of first instance is the same as that of the judgment of the court of first instance, Article 8(2) of the Administrative Litigation Act
It shall be quoted as it is in accordance with the main sentence of Article 420 of the Act.
○ At present by filing an appeal (Seoul High Court 2014Nu62892) that reduces the fourth column of the first instance judgment.
The appeal is pending (Seoul High Court 2014Nu62892) but on July 17, 2015, the appeal is filed.
The dismissal judgment was pronounced. An appeal was again filed by the Trade Union (Supreme Court Decision 2015Du48921), but September 2015.
15. The dismissal of the appeal was pronounced on the ground of the submission of the appellate brief.
○ “A Accounting Corporation” from the seventhst session of the first instance judgment until the seventh session multiplied by the fifth session.
"AA Accounting Corporation" is regarded as " September 8, 2008."
○ “Incompetence to trust” following the 13th sentence of the first instance court, which shall be multiplied by the said 13th sentence:
the value of assets on the balance sheet of the start of DD, which is difficult to believe, shall be divided;
(1) The book value of A AHaT, prepared immediately before the completion of the registration, shall be equal to the value of the stock of this case.
It shall add "not all errors that may not be found to exist in the foundation of the household."
2. Conclusion
If so, the plaintiff's claim shall be dismissed as it is without merit, and the judgment of the court of first instance shall conclude this conclusion.
Inasmuch as the Plaintiff’s appeal is justifiable, it is dismissed as it is without merit. It is so decided as per Disposition.
partnership.