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1. Attached Form 1, which the Defendants issued against the Plaintiffs, is subject to the imposition of each gift tax (including additional tax) as set out in the attached Table 1.
Reasons
1. Details of the disposition;
A. D Co., Ltd. (hereinafter “instant company”) was established on November 29, 199, and was engaged in real estate management business, etc.; and E Co., Ltd. (hereinafter “E”) was a corporation that is engaged in real estate development and implementation business, etc. as a subsidiary of the instant company; and was closed on May 31, 2016.
B. F holding 60,00 shares of the instant company and G holding 12,000 shares of the instant company, respectively, transferred 48,000 shares of the instant company to the Plaintiff, Plaintiff B, 12,000 shares, and 12,00 shares to Plaintiff C (hereinafter “instant shares”) on December 18, 2013.
C. From April 11, 2016 to May 25, 2016, the director of the Seoul Regional Tax Office: (a) deemed that the Plaintiffs acquired the instant shares without compensation; and (b) notified the Defendants of relevant taxation data; and (c) the Defendants determined and notified the Plaintiffs of gift tax (including additional taxes) pursuant to Article 63(1)1(c) of the former Inheritance Tax and Gift Tax Act (Amended by Act No. 12168, Jan. 1, 2014; hereinafter “former Inheritance Tax Act”) and Article 54 of the former Enforcement Decree of the Inheritance Tax and Gift Tax Act (Amended by Presidential Decree No. 25195, Feb. 21, 2014; hereinafter “former Enforcement Decree of the Inheritance Tax and Gift Tax Act”).
(hereinafter “each disposition of this case”). On August 1, 2016, the date of notification of the sequence 140,752,790 on August 1, 2016, the Plaintiff’s gift tax (including additional tax) by the Head of the District Tax Office of Gangwon District Tax Office (hereinafter “instant disposition”). B on August 3, 2016, the head of the District Tax Office of the District Tax Office of the District Tax Office of the Gu on August 1, 2016 23,458,790 on August 1, 2016
D. On March 16, 2017, the Plaintiffs were dissatisfied with each of the instant dispositions and filed a request for a trial with the Tax Tribunal on March 16, 2017, but were dismissed on June 14, 2017.
[Ground of recognition] Facts without dispute, Gap evidence 1, 2, Eul evidence 1 to 3, 7, 8, respectively.