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(영문) 서울행정법원 2014.01.24 2013구합6060
증여세부과처분취소
Text

1. As indicated in the separate sheet No. 1, the Defendants committed against the Plaintiffs on the aggregate of 16,811,544.

Reasons

1. Details of the disposition;

A. Plaintiff C, G, E, and D are children of Plaintiff A (hereinafter “Plaintiff A”) and their children, both Plaintiff A and their children, respectively.

) Plaintiffs H and I are Plaintiff B’s children (hereinafter Plaintiff B and their children) and “Plaintiff B’s children” in total.

) Co., Ltd. (hereinafter “J”)

(2) On April 23, 2001, the Plaintiff A and B acquired J on December 28, 2005 in the name of the Plaintiff’s pro-Japanese Lyun-gu, Seoyang-gu, Seoyang-gu as the purpose of software development service business, computer wholesale and retail business, etc. (hereinafter “Syun-gu”). On January 25, 2006, the Plaintiff and B acquired the name of the Plaintiff’s pro-Japanese Lyun (Syun-gu), and transferred the corporate location to Ma.

3) N Co., Ltd. (hereinafter “N”)

) The purpose of the Plaintiff A’s business is to invest, etc. in non-performing loans and low-evaluation shares in a company established on November 17, 2007 (capital 50,000 won). The current shareholder status is as follows. The shareholder status is as follows: (a) the share ratio of Plaintiff A himself 500 shares in non-high-name shares from the time of the establishment to the time of establishment of the shareholder; (b) 500 shares in the number of Plaintiff A 50 shares in non-high-name shares; (c) 500 shares 50 shares in Plaintiff A 2 and 500 shares; (d) 40 percent of Plaintiff D 4,00 shares 4,50 shares 4,500 shares in Plaintiff E-5 women 4,500 shares (hereinafter “O”) was to acquire all shares in a company subject to restructuring; and (d) the shareholder status was changed to Plaintiff B around November 207.

On May 16, 2006, the shareholders acquired 49% of the J's shares on November 23, 2007, from May 16, 2006, the share ratio of Plaintiff B 1,000 shares in non-high name-related shares of Plaintiff B, 5% representative, Plaintiff H 12,000 shares 60% of Plaintiff H heading H 12,000 shares, Plaintiff I women 7,000 shares, 35% N andO acquired 49% of the shares, respectively. The remaining 2% of the shares acquired from the P who is in charge of the plaintiffs' tax consulting, and the shareholders change details before and after the time are as follows:

The shareholder name of December 28, 2005 to Nov. 22, 2007, from Nov. 22, 2007 to Sept. 14, 2009 to Dec. 31, 2009, the share ratio of shares in the number of shares is reduced.

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