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(영문) 서울고등법원 2015.09.08 2015누43072

종합소득세부과처분취소

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1. The plaintiff's appeal and the plaintiff's claim added in the trial are all dismissed.

2. The costs of appeal and the costs of appeal.

Reasons

1. Details of the disposition;

A. The Plaintiff is a person operating a personal business with the trade name “B” from July 1, 1982 to the date.

B. The business operated by the Plaintiff (hereinafter “instant business”) is divided into three sectors, and the content of each sector and the estimated sales ratio are as shown in [Attachment 1].

[1] 60% of the sales agency contract with a foreign shipbuilding machinery manufacturer, issued a letter of promise to sell goods on behalf of a foreign shipbuilding company, and received profits from the import of the shipbuilding machinery and equipment from the domestic shipbuilding company, and then sold it in Korea, 15% of the price of the shipbuilding machinery and equipment sold by the plaintiff of the 15% technical advisory service, and 25% of the price for the shipbuilding machinery and equipment sold by the plaintiff of the 15% technical advisory service is paid.

C. From 2008 to 2012 (hereinafter “instant taxable period”), the Plaintiff employed C, D (hereinafter collectively referred to as “non-child employees”), E (the Plaintiff’s children’s children’s children’s children’s children), and F (hereinafter collectively referred to as “Plaintiff’s children’s employees”). D.

The details of payment of benefits, etc. and appropriation details of allowances for severance benefits to the above workers are as shown in [Attachment 2].

[Attachment 2] Name 2: 0. 30. 208. 2008. 31,920 36,020 - 36,000 - 36,762 - 36,700 - 36,900 - 36,9010 - 36,900 - 38,400 - 38,400 - 38,400 - 20142,501,500 - 201,503,500 - 2036,50,50 - 1,500 - 207,400 - 2042,500 - 42,500 - 430,500 - 430,500 -636,504