Criteria for determining the estimation of the amount of rent for private property;

In determining the estimated amount of the rent for a site owned by the Government, it shall be reasonable to determine the amount of the rent for a site by the example of the lease of the neighboring site, and the provisions of Article 25-2 of the Enforcement Rule of the State Property

Article 20 of the Corporate Tax Act, Article 33 of the Corporate Tax Act

International Fire Insurance Corporation

The director of the tax office

Seoul High Court Decision 71Gu25 delivered on November 1, 1972

The appeal is dismissed.

The costs of appeal shall be borne by the defendant.

Defendant’s Intervenor’s Grounds of Appeal

The first and second points are also examined.

The record states that the Defendant determined the omitted rent income and claimed as the basis for imposing the tax (in particular, the Defendant’s legal representative’s statement on February 22, 1972 stated at the time of the 11st oral argument of the lower court) that the Plaintiff committed an act of tax avoidance by failing to report the rent income despite the lease of the land owned by the Plaintiff to the Egypt Promotion Co., Ltd., the act of tax avoidance was denied, and the Plaintiff imposed tax pursuant to Article 20 of the Corporate Tax Act and the Enforcement Decree of the same Act, but calculated the omitted rent income pursuant to Article 25-2 of the former Enforcement Rule of the State Property Act in the same manner as the State Property Act provides for the determination of rent of the pertinent State property only in the absence of actual rent of the neighboring land, and the provision of Article 25-2 of the former Enforcement Rule of the State Property Act is reasonable and reasonable in determining that the above provision is the most reasonable and reasonable ground for calculating the rent of the Plaintiff’s neighboring property under the premise that the above provision should not be applied to this case’s reasonable and reasonable reasoning.

Therefore, the appeal is dismissed. It is so decided as per Disposition by the assent of all participating judges by applying Articles 95 and 89 of the Civil Procedure Act to the burden of the costs of appeal.

Justices Kim Young-ba (Presiding Justice)