Seoul Administrative Court-2017-Gu Group-68731 ( October 01, 2018)

Taxation on the conversion price as the acquisition price is not verified;

The actual acquisition value of land is not known, and there is no reliable appraisal value assessed by two or more appraisal corporations or appraisal values of assets which are identical or similar within three months before and after the date of acquisition of land, and it is appropriate disposition taxable as the conversion value of acquisition.

Article 97 of the Income Tax Act

2018Nu4837 Demanding the revocation of disposition imposing capital gains tax

OO

b Head of the Tax Office

Seoul Administrative Court Decision 2017Gudan68731 decided May 1, 2018

November 9, 2018

January 11, 2017

1. The plaintiff's appeal is all dismissed.

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

The judgment of the first instance shall be revoked. The imposition of capital gains tax of KRW 45,788,110 (including additional tax) on the Plaintiff on December 13, 2016 by the Defendant shall be revoked.

1. Quotation of the reasons for the judgment of the first instance;

The reasons for this decision are as follows: (a) The reasons for this decision are as follows: (b) Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

○ 14 pages 14 "No. 1" are raised as "No. 1, 12 and 15."

The ○ 5 side 5 side 5 side , "witness", shall be regarded as "witness of the first instance trial".

2. Conclusion

If so, the plaintiff's claim shall be dismissed as it is without merit. The judgment of the court of first instance is just with this conclusion, and the plaintiff's appeal is dismissed as it is without merit.