증여세부과처분취소
1. All appeals filed by the plaintiffs are dismissed.
2. The costs of appeal are assessed against the Plaintiffs.
The purport of the claim and appeal is the purport of the appeal.
1. Details of the disposition;
A. Title trust 1) C Co., Ltd. (hereinafter “C”).
The trade name before the change is Qua Stock Company.
(2) On May 17, 2001, Plaintiff B acquired the total amount of KRW 228,00,000 shares issued by C from D and E on April 28, 2009, under title trust in the name of G, etc. on or around June 15, 2009. On March 13, 2013, the title trust was made with Plaintiff A with the total amount of KRW 84,360 shares issued by G, which was held in title trust with G, and the details indicated below are as follows.
Plaintiff B, in 2012, 2013, F 47,880 F 54,720 F 54,720 F 54,720 C 47,880 H 47,880 H 47,880 H 47,880 I 41,040 I 41,040 I 41,040 C G 43,320 G 84,360 G 040 G 0, J 040 J 41,00 J 41,040 G 84,360 C 0 J 0 J 0, the total of 228,200,2200,200, the total of 228,000 of the present representative directors of Plaintiff A0 A 84,360 C 228,00
B. At the time of February 21, 2012, Plaintiff B acquired 40,000 shares of CO of a stock company from V on June 28, 2011, that the trade name was “O of a stock company” as of November 23, 2015 (see Evidence A No. 11).
The 98,000 shares issued by this was under title trust with L, R, etc., but on February 21, 2012, the 34,300 shares issued by L was under title trust with the Plaintiff A.
C. On August 30, 2012, Plaintiff B acquired 6,000 shares out of 20,00 shares issued by Plaintiff M Co., Ltd. (hereinafter “M”), and received 6,600 shares out of 22,00 shares issued by M with capital increase on the same day (as stock holding ratio, allocated by Plaintiff A), and received 12,600 shares in total among 18,00 shares issued by M with capital increase on September 24, 2013, and received 5,40 shares out of 18,00 shares issued by M with capital increase on September 24, 2013 (F, U, and allocated by Plaintiff A according to the share holding ratio) and received 18,00 shares out of 18,00 shares out of 18,00 shares issued by each title trust to Plaintiff A.