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(영문) 서울행정법원 2017.09.21 2017구합65456
세무조사결정처분취소
Text

1. The plaintiff's claim is dismissed.

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

Reasons

1. Details of the disposition;

A. On February 1, 2016, the Plaintiff, a corporation that runs the wholesale and retail business of electronic equipment, the wholesale and retail business of communications equipment, etc., and the head office of Dobong-gu Seoul Metropolitan Government, the head office of which is located in 248-1 (windong), Seo-gu, Seoul, Seoul, 507, 1903 (Renal Dong-dong, Sung-dong 3).

B. On February 22, 2017, the Defendant notified the Plaintiff that a tax investigation should be conducted as follows pursuant to Article 81-7(1) of the Framework Act on National Taxes and Article 63-6 of the Enforcement Decree of the same Act, on February 22, 2017, deeming that the Plaintiff’s report constitutes a case where the Commissioner of the National Tax Service regularly analyzes the degree of loyalty on the taxpayer’s return pursuant to Article 81-6

(2) A tax investigation conducted on January 1, 2013 to December 31, 2013: A tax investigation conducted on March 6, 2017 to April 9, 2017: A tax investigation conducted on the following grounds: A tax investigation conducted on the grounds that the Commissioner of the National Tax Service, pursuant to Article 81-6 (2) 1 of the Framework Act on National Taxes, regularly analyzes the details of a taxpayer’s return and, as a result, is suspected of false tax investigation;

C. On March 20, 2017, the Plaintiff appealed and filed a request for a trial with the Tax Tribunal. However, on May 23, 2017, the decision on the instant tax investigation was dismissed on the ground that “the instant decision is of the nature of the prior notification of the disposition and is not an object of objection.”

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 2 and 4 (including branch numbers, hereinafter the same shall apply), the purport of the whole pleadings

2. Whether the disposition is lawful;

A. A. Around November 2014, the Plaintiff’s head of Nowon-gu Tax Office conducted a post-verification on the part of the value-added tax 1 in 2013 against the Plaintiff. This is a communications company’s sales data.

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