National Tax Service Review Corporation 201-0050 ( December 30, 2011), National Tax Service Review Corporation

It is difficult to deem that wages, etc. have been paid because data on expenditures are not appropriated as losses in the settlement of accounts or books;

Expenses claimed by a corporation are not included in the expenses of the settlement of accounts or books, and there is no objective data on the expenditure, such as the details of financial transactions, so it is difficult to regard that wages, etc. were paid.

2012Guhap104 Revocation of Disposition of Corporate Tax Imposition

AA Tax Accounting Corporation

Head of Changwon Tax Office

June 21, 2012

July 12, 2012

1. The plaintiff's claim is dismissed.

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

The Defendant’s disposition of imposing corporate tax of KRW 000 against the Plaintiff on June 1, 201, which exceeds KRW 000, shall be revoked.

1. Details of the disposition;

A. The Plaintiff is a tax accounting corporation that reports taxes, files applications, and files claims on behalf of the Plaintiff.

B. From March 9, 2011 to April 12, 201 of the same year, the Commissioner of Busan Regional Tax Office conducted a general consolidated investigation against the Plaintiff, and notified the Plaintiff to impose corporate tax on the amount appropriated for and the amount omitted from sales. On June 11, 2011, the Defendant issued the instant disposition imposing corporate tax (00 won for the year 2008, 000 won for the year 2009, and 000 won for the year 2010) on the Plaintiff.

C. The Plaintiff filed a request for examination with the National Tax Examination Committee, but the said Committee dismissed the Plaintiff’s request on December 30, 201.

[Reasons for Recognition] The descriptions of Gap evidence 1, Eul evidence 1, 2, and 3, and the whole purport of the pleading

2. Whether the instant disposition is lawful

A. The plaintiff's assertion

(1) The disposition of this case is unlawful unless it recognizes the total of KRW 000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,000,00

(b) Related statutes;

Paper in the Appendix

C. Determination

The entries in Gap evidence 2 through 7 alone lack to admit the plaintiff's assertion, there is no other evidence to acknowledge it, and instead, the expenses alleged by the plaintiff are not appropriated in the plaintiff's account settlement or account book as deductible expenses, and the plaintiff does not submit objective data on its expenditure, such as financial transaction details (the copy of the passbook submitted as data on construction cost cannot be viewed as the plaintiff's deductible expenses, as the details paid by the plaintiff's representative), and it is difficult to view that the plaintiff paid wages, etc. as argued by the plaintiff. Thus, we cannot accept the plaintiff's assertion.

3. Conclusion

The plaintiff's claim is dismissed for lack of reason.