beta
Text
1. On February 17, 2014, the Defendant notified the change of the income amount of KRW 2,952,515,075 against the Plaintiff.
Reasons
1. Details of the disposition;
A. On March 25, 2005, the Plaintiff and C’s representative director C acquired KRW 60,000 per share of KRW 20,000,000 per share by participating in D’s capital increase with capital increase on March 25, 2005. According to the statement of stock change, C shall be deemed E and F (hereinafter “E, etc.”) around 2006.
Each 30,000 shares are transferred to 30,000 shares, E, etc. are transferred to G Co., Ltd. (hereinafter “G”) around 2007.
(2) On February 17, 2006, the Plaintiff participated in D’s capital increase with capital increase and acquired KRW 50,000 per share total of KRW 40,000 per share in KRW 2 billion.
(hereinafter “instant shares”). According to the statement on the change of shares, the Plaintiff indicated that around 2006 the said shares were transferred to H and seven persons, and H and seven persons (H) transferred the said shares to G around 2007.
3) C’s ASEAN and three others transferred D’s 60,000 shares to G around 2007. (b) The Director of the Seoul Regional Tax Office (C) examined D’s share fluctuation from March 8, 2010 to July 2, 2010, and transferred C’s total 170,000 shares (5.19% of the total shares issued) and management right of KRW 170,000 (118,908 won per share) to G through H and seven others, and C determined that C’s taxation data were under-reported by transfer of shares to G, and notified the relevant Office thereof.
2) On March 26, 2007, the Defendant determined that the Plaintiff transferred the instant shares to G (i.e., KRW 118,908 per share x KRW 50,000 per share x KRW 118,900 per share x 50,000), and included the amount obtained by subtracting the transfer proceeds, etc. already reported in gross income. On August 2, 2010, the Seoul Regional Tax Office imposed KRW 84,690,690, and securities transaction tax of KRW 11,890,80 for the business year 2007 on the Plaintiff. 3) on August 1, 2010, the Seoul Regional Tax Office imposed KRW 2,992,84,9250 for the Plaintiff among the said transfer proceeds, and KRW 2,952,515,075 for the remainder not paid by the Plaintiff.