A. Whether only a part of the intended business of the company constitutes a person who succeeded to all rights and duties regarding the business comprehensively under Article 41 of the Framework Act on National Taxes and Article 22 of the Enforcement Decree of the same Act (negative)

B. Meaning of the provision that succeeds to all rights and obligations of the constructor under Article 11(1) of the Electrical Construction Business Act

(a) a license for the electrical construction business, which is only a part of the intended project of society, and a transferee of only sections for that project shall not be a person who has succeeded to all rights and obligations relating to that project comprehensively under Article 41 of the Framework Act on National Taxes and Article 22 of its Enforcement Decree;

B. Whether a constructor succeeds to all the rights and obligations of the constructor under Article 11(1) of the Electrical Construction Business Act shall not be deemed to be the transferee who comprehensively takes over the business even if it does not succeed to all the rights and obligations of the constructor in case of a transfer of construction business, but it does not mean that the transferee is the transferee who comprehensively takes over the business.

(a) Article 41 of the Framework Act on National Taxes and Article 22 of the Enforcement Decree of the Framework Act on National Taxes;

(b) Supreme Court Decision 82Nu311 delivered on April 24, 1984

[Judgment of the court below]

Head of North Korean Tax Office

Seoul High Court Decision 84Gu45 delivered on July 31, 1984

The appeal is dismissed.

The costs of appeal are assessed against the defendant.

The grounds of appeal are examined.

According to the reasoning of the judgment below, the court below found that the non-party company established for the purpose of the sale business of electrical appliances and its incidental business after compiling the acquired the above non-party company's first-class electrical construction business license (license number omitted) and the first-class construction business license for the non-party company's first-class electrical construction business (license number omitted) and the second-class construction work section 47, including the legal section 28 of the company's ownership from the non-party 1 company's second-class company's second-class company's second-class company's second-class company's second-class company's first-class company's second-class company's second-class company's second-class company's second-class company's second-class company's second-class company's second-class company's second-class company's second-class company's second-class company's second-class company's second-class company's second-class company's second-class company's second-class company's second-class company's business's second company's second-class company's second company's company's second company's company's company's second company's company's second company's company's second.

Ultimately, since the appeal is without merit, the appeal is dismissed. It is so decided as per Disposition by the assent of all participating Justices.

Justices Jeon Soo-hee (Presiding Justice)