logobeta
본 영문본은 리걸엔진의 AI 번역 엔진으로 번역되었습니다. 수정이 필요한 부분이 있는 경우 피드백 부탁드립니다.
텍스트 조절
arrow
arrow
(영문) 광주지방법원 2014.12.18 2014구합10141
종합소득세부과처분취소
Text

1. On July 3, 2013, the Defendant imposed global income tax of KRW 153,388,710 (including additional tax) on the Plaintiff for the year 2009.

Reasons

1. Basic facts

A. The Plaintiff loaned money to B over several occasions from December 2008 to March 2009, and, under mutual agreement, drafted a loan certificate for four times as described in the following table Nos. 1 to 4, and confirmed the obligation to repay to the Plaintiff by B as totaling KRW 950,000,000 (hereinafter “the interest of this case”) and the agreed interest amounting to KRW 345,00,000,000 (hereinafter “the interest of this case”). In addition, as described in the table No. 5, as indicated in the table No. 5, the Plaintiff additionally lent KRW 30,00,000 to B on March 9, 2010 as indicated in the table No. 5.

(4) The loan agreement of 10,000 won in total 150,000 won on May 11, 2009; 150,000 won in total 150,000,000 won in total 150,000 won in total 30,000,000 won in total 150,000,000 won in total, on November 3, 2009; 150,000 won in total 150,000,00 won in total 150,000,00 won in 10,000 won in each case; 150,000,00 won in total on July 3, 2009; 200, 2000 won in total 150,000,000 won in 250,50,00 won in total;

B. Around March 2013, the Defendant imposed global income tax on the Plaintiff: (a) conducted a general investigation of global income tax for the year 2009 on the Plaintiff; (b) on July 3, 2013, the Defendant calculated the interest income, including the instant interest, which is a non-business profit, as KRW 347,00,000; and (c) determined and notified the global income tax for the year 2009, calculated based thereon as global income tax of KRW 153,38,710 (including additional tax).

(hereinafter referred to as the “instant disposition”). (c)

The Plaintiff was dissatisfied with the instant disposition and requested to the Tax Tribunal for a trial on July 3, 2013, but was dismissed on December 9, 2013.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 4, Eul evidence Nos. 1 and 2 are included below.

arrow