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Case Number of the immediately preceding lawsuit
Changwon District Court 2008Guhap2314 ( October 19, 2009)
Case Number of the previous trial
Cho High Court Decision 2008Da1056 (Law No. 86.30)
Title
Whether a person with a special relationship is a person with a special relationship in any direction or in any manner;
Summary
In case where a person does not fall under a specially related person on the basis of one party, two corporations are deemed to fall under a specially related person on the basis of the other party.
The decision
The contents of the decision shall be the same as attached.
Text
1. The plaintiff's appeal is dismissed.
2. The costs of appeal shall be borne by the Plaintiff.
Purport of claim and appeal
The decision of the first instance shall be revoked. The defendant shall revoke the disposition of imposition of KRW 151,496,50 of the corporate tax of 2004 against the plaintiff on February 1, 2008, KRW 130,224,880 of the corporate tax of 2005, and KRW 110,103,570 of the corporate tax of 2006.
Reasons
The court's explanation of this case is the same as the reasoning of the judgment of the court of first instance. Thus, this court's explanation is acceptable in accordance with Article 8 (2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.
Therefore, the judgment of the court of first instance is legitimate, and the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.