종합소득세부과처분취소
1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
1. Details of the disposition;
A. The Plaintiff, a business proprietor operating the housing construction and sales business, constructed and sold each of the instant housing units (hereinafter collectively referred to as “each of the instant housing”) as indicated in the following table with joint business operators:
The sales year from the date the commencement date of construction of joint housing business operators of each of the instant cases begins is the Gangseo-gu Seoul Metropolitan Government Urban Living Housing ( Complex Multi-household) A (hereinafter “First Housing”) and the Gangseo-gu Seoul Metropolitan Government D Urban Living Housing ( Complex Multi-household) (hereinafter “Second Housing”) on September 26, 2015, September 2015, 2015; and E on October 20, 2015, 2016. < Amended by Presidential Decree No. 27779, Nov. 24, 2016>
B. In the event that the amount of income falls short of the amount prescribed in Article 143(4)2(b) of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 26982, Feb. 17, 2016; hereinafter the same shall apply) at the taxable period immediately preceding the pertinent year, the Plaintiff registered the business as follows, and accrued the sales revenue for each of the instant housing, and accordingly, the Plaintiff calculated the estimated income by applying the simple expense rate under the above provision and paid the comprehensive income tax accordingly.
The amount of income accrued from October 10, 2014 (F) December 17, 2014 (F) 700,000 on December 17, 2014) of the instant first Housing Act, which was the item sales day (sales day) item (sales day) item sales day of the instant case, shall be the amount of income accrued from October 27, 2015 of the instant second Housing Act, which was the amount of income accrued from October 27, 2015 (G) 201,000
C. From August 8, 2017 to September 16, 2017, the director of the Seoul Regional Tax Office, upon conducting a tax investigation with respect to the Plaintiff, notified the Defendant of the amount of income calculated by estimation based on “standard expense rate” by deeming that the Plaintiff is not subject to the application of simple expense rate. Accordingly, the Defendant, on November 1, 2017, notified the Plaintiff of the correction of global income tax of KRW 63,89,630 (including additional tax), global income tax of KRW 63,89,630 (including additional tax), global income tax of KRW 211,04,860 (including additional tax) for the year 2016.
(hereinafter “instant disposition”) D.