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1. Additional tax for the Defendant’s failure to report KRW 190,867,50 for the gift tax for the year 2007 owed to the Plaintiff on April 1, 2014, 36,000.
Reasons
1. Details of the disposition;
A. On October 13, 2006, the plaintiff is the non-party B's spouse, and the non-party C, the branch of which is the non-party B, acquired D's new shares 500,000 shares (50 billion won per acquisition price, 250,000 won per share, 200,000 won per share; hereinafter "the non-party A's new shares") in the name of the plaintiff at the time of issuing new shares of the non-party B's purchase bank (hereinafter "D"), and in relation to the non-party A's non-party E (the non-party A's dissolution on October 7, 2008; hereinafter "E"), with respect to the non-party A's new shares 1,00,000 shares per share (50 billion won per share, total acquisition price, 50,000 won per share, hereinafter "the non-party B's new shares acquired 30,500,000 won per share).
B. The Seoul Regional Tax Office conducted a tax investigation with respect to C from May 13, 2013 to December 20, 2013, and deemed C to have held title trust with respect to the Plaintiff, and notified the Defendant of the imposition of gift tax with respect to the Plaintiff in accordance with the provision on deemed donation of title trust property under the Inheritance Tax and Gift Tax Act.
C. Accordingly, on April 1, 2014, the Defendant imposed gift tax on the Plaintiff as follows.
Disposition of imposition of D 103,034,470 No. 2 on October 3, 2006 of the amount of tax (unit of won) issued on the separate donation date, which is a disposition of imposition of D 103,034,470 on May 16, 2007, E 277,712,210 No. 3, October 22, 2007, E 209,274,390 on the aggregate of 590,021,070
C. The Plaintiff appealed and filed an appeal with the Tax Tribunal on June 30, 2014. However, the Tax Tribunal dismissed the Plaintiff’s appeal on November 26, 2014.
On June 2, 2015, the Defendant revoked the first disposition on the shares of the instant case on June 2, 2015, and the amount of the second disposition is KRW 190,867,500 (including additional taxes of KRW 36,000,000 and additional taxes for unfaithful payment, and KRW 64,867,500), the tax amount of the third disposition is KRW 186,574,50 and additional taxes for unfaithful payment of KRW 36,00.0.