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(영문) 서울행정법원 2016.11.25 2014구합55731
종합소득세부과처분취소
Text

1. All of the plaintiff's claims are dismissed.

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

Reasons

1. Details of the disposition;

A. B (hereinafter referred to as the “instant company”) changed the name of the company into the compact after the KT Co., Ltd. (hereinafter referred to as “K”) and the Ecom Co., Ltd. (hereinafter referred to as “Ecom”), which is a key telecommunications business operator, and the name of the company was changed to the Lcom Co., Ltd. (hereinafter referred to as “Ecom”). The Lcom Co., Ltd. merged the Comcom with the Lcom Co., Ltd. and the Lcom Co., Ltd., and changed its trade name to EL Plu

After the global tax communication, the trade name was changed to the Onnuri Telecom Co., Ltd. (after that, the merger was made to the Yucom Co., Ltd., but the merged corporation had its trade name changed to the Onnuri Telecom), and the Sejong Telecom Co., Ltd. combined the Onnuri Telecom.

(hereinafter referred to as “heat communications,” respectively, entered into a telephone information service contract with the case, telecom, and Onnuri communications, and provided the information users with telephone information services, such as voice hosting, securities information, and traffic consultation (hereinafter referred to as “instant services”).

From May 2, 2007 to December 31, 2009, the Plaintiff served as the representative director of the instant company.

B. The instant company filed a report on the tax base and tax amount of corporate tax from 2007 to 2009, and included the revenue amount of information usage fees from the provision of telephone information services through radio phones (hereinafter “the sales amount of radio minute information usage fees”). However, the sales amount of information usage fees from the provision of telephone information services through wire phones (hereinafter “sales amount of information usage fees”) was omitted from the revenue amount.

C. On January 2, 2012, the Defendant: (a) pertaining to the sales amount of the information usage fee of the instant company ( KRW 958,615,060 for the business year 2007, KRW 554,926,550 for the business year 2008, and KRW 536,90,507 for the business year 2009).

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