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(영문) 서울행정법원 2015.10.30 2014구합22229
종합소득세부과처분취소
Text

1. On May 21, 2013, the Defendant imposed global income tax of KRW 57,226,540 (including additional tax) on the Plaintiff for the year 2009.

Reasons

1. Details of the disposition;

A. The Plaintiff loaned to B KRW 40 million on March 6, 2008, KRW 20 million on March 14, 2008, and KRW 20 million on March 14, 2008, respectively, after two months of the due date, and at 3% of the interest rate per month.

(1) The sum of each of the above loans is KRW 420 million (hereinafter “instant loan”). C, on March 6, 2008, concurrently acquired KRW 400 million as the above loan debt of KRW 20 million and KRW 20 million as the above loan debt of KRW 20 million on June 25, 2008.

B. On March 27, 2009, the Plaintiff received respectively payment of KRW 85 million from D, the father of C (hereinafter “instant amount”) and KRW 50 million from C on July 23, 2009 (hereinafter “instant amount”).

C. On May 27, 2009, the Plaintiff purchased the instant loan and its interest in KRW 450,000,000,000,000,000 for KRW 550,000,000,000,000,000 for KRW 1,000,000,000,000 for KRW 1,000,000,000,000 for KRW 1,000,000,000,000 for KRW 1,000,000,000,000,000,000,000,000,000,000,0000,000,000,000,000,000,000,000,000,000,000,00,00,000.

(2) On May 27, 2009, the Plaintiff purchased the instant land and housing from C on May 27, 2009, and on the same day, purchased the instant land and housing in the name of G, and on November 26, 2009, registered the right to claim ownership transfer on November 26, 2009, with respect to the instant land and housing No. 2, based on a trade reservation.

However, as C did not deliver the second floor of the instant housing No. 1, the Plaintiff agreed with D and H on September 16, 2009 to re-purchase the instant housing No. 1, 2 and housing by October 10, 209.

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