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1. The Defendant, on November 2, 2012, is the secondary taxpayer of the Plaintiff (Appointed Party) and the designated parties as the secondary taxpayer of the Plaintiff Company B.
Reasons
1. Details of the disposition;
A. From November 17, 2003 to November 27, 2009, the Plaintiff (Appointed Party; hereinafter “Plaintiff”) was registered as the representative director of C Co., Ltd. (hereinafter “instant company”), an unlisted corporation, as the representative director from November 17, 2003 to November 27, 2009. From November 27, 2009 to August 5, 2010, the Plaintiff owned 5,000 shares out of the total number of outstanding shares of the instant company, and the Plaintiff’s wife D owned 10,00 shares of the instant company from November 17, 2003 to March 10, and owned 150 to March 10, 206, and the Plaintiff’s wife owned 1500 shares of the instant company from November 27, 2003 to March 10, 2006 to 150 shares of the instant company.
B. On July 14, 2010, the Plaintiff and the designated parties (hereinafter “Plaintiffs, etc.”) of the instant company entered into a stock transfer agreement with the AsssPPAC Co., Ltd. (hereinafter “AsPPA”) to transfer all of the management rights and shares of the instant company to KRW 10,000 (Plaintiffs 5,000 shares, designated parties, 1,500 shares, and 2,000 shares, respectively) with F, G, and H (hereinafter “transferee”) on July 14, 2010. The main contents of the agreement are as follows.
The total amount of the price shall be KRW 2.9 billion, and the transferee shall succeed to the claim of KRW 3207 billion, such as the security deposit, and KRW 2.477 billion, and the difference shall be KRW 747 billion, and the transferor shall be paid KRW 7.7 billion ( KRW 2.99 billion - KRW 2.47 billion - KRW 2.47 billion).
The transferee shall additionally pay KRW 2 million for the acquisition cost of the PC for the PC and KRW 3 million for tax-related adjustment.
The contract date shall be July 15, 2010, and the transferor shall be all the change debts not mentioned in the assignee's responsibility and all the expenses incurred before July 15, 2010.