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Reasons
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(영문) 서울행정법원 2017.06.23 2015구합83122
증여세부과처분취소
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1. The Defendants’ “date of Notice” as set out in the separate sheet No. 1 is limited to the Plaintiff on each corresponding date.

Reasons

1. Details of the disposition;

A. On December 15, 1965, the Plaintiff’s attached B established C Co., Ltd. (hereinafter “instant company”).

B. The 2,202,540 shares issued by the instant company (hereinafter “the instant shares”) were registered in the name of D, a corporation located in Hong Kong (hereinafter “D”). However, the total D shares were registered in the name of E (hereinafter “E”) and F (hereinafter “F”). On June 23, 1993, there was a trust declaration that the instant shares were held in the name of F, 1 share, E’s ownership and beneficial rights to one share, and the real owner of D shares and shares issued in the instant shares.

C. The deceased B died on February 20, 2007, and as the deceased’s co-inheritors, the Plaintiff (G) and his spouse H (Death on November 4, 201), and his married I (J). On August 7, 2007, the above co-inheritors prepared a written agreement on division of inherited property (hereinafter “instant written agreement on division”), and reported the inheritance tax amounting to KRW 7,25,116,167 to the head of Sungbuk Tax Office on August 22, 2007.

A written agreement on division of inherited property is the date of the death report on March 2, 2007.

With respect to the inheritance of the property owned by the decedent B that began due to the death of the decedent B, the co-inheritors H, I, and the Plaintiff shall make a final agreement on the division of the inherited property as shown in the attached Form attached to this Section, and shall prepare three copies of the agreement in order to verify the fact of such agreement and have one signature and seal as follows:

(Attached) Details of the division of inherited property

1. The heir's inherited property divided with H (1) 1,735,82,606 won (the account number omitted; hereinafter the same shall apply) deposit at the Ulsan Central Branch in the Bank of Korea (5) 4,353,934 won (6) 63,596,431 won (7) N in the Ulsan Branch in the Foreign Exchange Bank.

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