Whether the actual attribution of the amount omitted in filing a return on stock sales income constitutes a corporation

Inasmuch as the attribution of income is nominal and factually the assertion of the person to whom income accrues is not based on the burden of proof to the person who asserts it, this disposition to which income belongs to the corporation is legitimate.

Article 4 of the Corporate Tax Act

1. The plaintiff's appeal is dismissed.

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

The decision of the first instance court is revoked. The defendant's disposition of imposing corporate tax (708,594,830 won) in 1999 against the plaintiff on December 1, 2004 and the disposition of imposing securities transaction tax (6,827,970 won) in December 1999 is confirmed to be null and void.

This Court's reasoning is the same as that of the first instance court's decision, except where "the fifth 14th th th th th th th th th th th th th th th th th th th th th th th th th of the first instance court's decision is used."

Therefore, the judgment of the first instance court as to this conclusion is legitimate, and the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.