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Reasons
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(영문) 서울행정법원 2015.12.17 2015구합68864
증여세등부과처분취소
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1.(a)

On December 1, 2014, the director of the tax office of Asan imposed a gift tax of 106,922,450 won on Plaintiff A in 2008.

Reasons

1. Details of the disposition;

A. From June 12, 200 to November 30, 201, E respectively held title trust with the Plaintiffs and G, for the aggregate of 636,365 shares in the F Co., Ltd. (hereinafter “instant company”)’s non-listed shares as indicated in the following table (hereinafter “instant shares”).

(3) On September 15, 2008, in the case of title trust, E acquired the shares of the company in its own name from a third party, and otherwise, E acquired the shares of the company in its own name from a third party, and thereafter purchased the shares of the company in its own name and purchased the shares of the company in its own name, and Plaintiff B, Plaintiff D Co., Ltd (2,500 2,500 60,500 606,000 66,000 on June 12, 200, 100 93,50,500 66,506,630,606,606, 606, 506, 506, 606, 630, 606, 606, 500, 6306, 605, 200, 1200, 10, 3008, 2005

Plaintiff

B는 E의 처, 원고 A, D는 E의 처남, 원고 C은 E의 처남댁, G은 E의 장모이다.

C. On March 29, 2012, E sold the entire shares of the instant case to H, and reported and paid each transfer income tax on the transfer of shares in the names of the Plaintiffs and G except Plaintiff D.

After that, from September 11, 2014 to October 10, 2014, the director of the Incheon District Tax Office conducted an investigation of capital gains tax, and the Defendants determined and notified each of the Plaintiffs on the ground that E each of the instant shares was held in title trust with the Plaintiffs and G (as the G dies, gift tax reverted to G was notified to the Plaintiff A, the heir, and the gift tax reverted to G in the year 2000) as stated in the attached disposition of imposition.

(including additional tax, hereinafter “each disposition of this case”). E

The Plaintiffs were dissatisfied with each of the instant dispositions by the Defendants and filed an appeal with the Tax Tribunal on January 30, 2015 and February 6, 2015, respectively, but all of the appeals were dismissed on May 21, 2015.

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