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1. The judgment of the first instance, including the Plaintiff’s claim that has been exchanged before the remand, is as follows.
Reasons
1. Details of the disposition;
A. The director of the Daegu Regional Tax Office confirmed that B lent 1.7 billion won of interest income from April 26, 2004 to December 28, 2004 (B: 69 billion won of interest income from April 26, 2004; 1.75 billion won of income from August 22, 2006 to December 11, 2007; 3.179 billion won of income from August 2, 2006 to December 11, 2007; and then, based on Article 45.9-2 of the Enforcement Decree of the Income Tax Act, the Plaintiff notified the Defendant of 1.6 billion won of tax income from 2004 to 2007 (1.5 billion won of income from August 26, 2004; 3.6 billion won of income from August 26, 200, 205; 3.6 billion won of income from rent of 2.6 billion won of income from KRW 3 million of KRW 3.6 million of
B. On March 1, 2009, the Defendant notified the Plaintiff of the correction of the global income tax of 783,302,970 won (66,830,360 won reverted to the year 2004,263,282,240 won reverted to the year 2005, 233,796,590 won reverted to the year 2006, and 219,393,780 won reverted to the year 2007) based on the above notification data.
(hereinafter referred to as the “previous Disposition”). C.
On May 25, 2009, the Plaintiff filed an appeal with the Tax Tribunal on May 25, 2009. The Tax Tribunal recognized that the Plaintiff’s interest income on both the loan amounting to KRW 690 million received from B and KRW 982 million received from C is an interest income on both the loan amounting to KRW 982 million, and determined that the interest on the loan amount to KRW 2 cannot be deemed to have occurred since it constitutes a claim that cannot be recovered due to the debtor’s business discontinuance, etc., and determined that the interest on the loan amounting to KRW 1.75 billion cannot be deemed to have occurred, and that the agreement on the loan amounting to KRW 1.75 billion against B should be corrected by deducting the tax base and tax amount to KRW 690,000,000,000,000 for the loan amounting to KRW 1.79,000 (
Meanwhile, on the other hand, the Defendant notified the Plaintiff of the income data by recognizing solar materials Co., Ltd. on January 5, 2010 (hereinafter “Trut materials”).