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(영문) 서울고등법원 2017. 07. 17. 선고 2017누249 판결

(1심 판결과 같음) 8년 자경감면 및 대토감면에서 자경여부에 대한 입증책임은 원고에게 있음[국승]

Case Number of the immediately preceding lawsuit

Chuncheon District Court-2016-Gu Partnership-221 ( October 20, 2017)

Case Number of the previous trial

Cho-2015-China-5031 (2016.04)

Title

(As with the judgment of the court of first instance) The burden of proving whether or not the self-defensive is self-defensive in the reduction and exemption of eight years

Summary

(The same as the judgment of the first instance court) The laws and regulations on the requirements for non-taxation or reduction should be strictly interpreted. In this regard, the burden of proving the existence of the self-taxation or reduction in 8 years and the existence of the self-sufficiency or reduction in large land is borne by the plaintiff, but the plaintiff cannot be fully proven

Related statutes

Article 69 of the Restriction of Special Taxation Act (Reduction or Exemption of Transfer Income Tax for Self-Cultivating Farmland)

Article 70 of the Restriction of Special Taxation Act for Substitute Land for Farmland

Cases

(Chuncheon)Revocation of disposition of revocation of imposition of capital gains tax

Plaintiff and appellant

AA

Defendant, Appellant

BB Director of the Tax Office

Judgment of the first instance court

Chuncheon District Court Decision 2016Guhap221 Decided January 20, 2017

Conclusion of Pleadings

June 19, 2017

Imposition of Judgment

July 17, 2017

Text

1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

The judgment of the first instance shall be revoked. The imposition of capital gains tax of KRW 101,302,678 against the plaintiff on January 5, 2016 by the defendant shall be revoked.

Reasons

1. Quotation of judgment of the first instance;

The reasoning for the court's explanation on this case is the same as that for the judgment of the court of first instance, and therefore, it is not sufficient to recognize a violation of the principle of trust protection because it is unclear whether the plaintiff made an answer to the reduction of capital gains tax (such as how the plaintiff made a registration of business with his domicile in ○○, etc.) by asking the public officials belonging to the defendant for any content of this case (such as explaining the circumstance that the plaintiff made a registration of business with his domicile in ○○, etc.), and thus, by the main text of Article 8 (2) of the Administrative Litigation Act, Article 420 of the Civil Procedure Act and Article 420 of the Civil Procedure Act.

2. Conclusion

Therefore, the judgment of the first instance is just, and the plaintiff's appeal is dismissed as it is without merit, and it is so decided as per Disposition.