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1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
Reasons
1. Details of the disposition;
A. 1) B A Co., Ltd. (hereinafter “C”) engaging in real estate lease management business, etc.
D Co., Ltd. (hereinafter “D”) engaged in internal directors and building construction business
(2) The Plaintiff, as a spouse of B, was registered as an internal director on the corporate register of C and was cancelled on March 2020, and is currently registered as D’s internal director.
B. 1) B’s father E died on February 8, 2017, and the Seoul Regional Tax Office conducted an inheritance tax investigation related to B, the director of the Seoul Regional Tax Office from February 28, 2018 to May 30, 2018, and conducted a tax investigation related to B’s donation (from February 28, 2003 to December 2016, 2016) to the Plaintiff and children derived from the above investigation. 2) As a result of the tax investigation related to the gift tax, the Seoul Regional Tax Office reported that the Plaintiff notified the Defendant of the aggregate amount of KRW 1,950,290,000,000,000,000,000,000 won (long-term loan (long-term loan) for C and D’s name, repayment of loan obligations under the Plaintiff’s name, purchase price of apartment housing (hereinafter “instant apartment”), purchase price, purchase price of financial products, KRW 1,950,194,29696,29700 million (i.
C. According to the notice of the result of the tax investigation on imposition of gift tax, the Defendant: (a) deemed that the amount of each transfer indicated in the column for “the amount of gift tax” (hereinafter “the amount of transfer in this case”) was donated to the Plaintiff on each date indicated in the table “the date of receipt” as indicated below; and (b) issued a disposition imposing KRW 1,047,05,780 on August 1, 2018 (hereinafter “each disposition in this case”).
G CD C I H
D. On October 29, 2018, the Plaintiff was dissatisfied with each of the dispositions of this case and filed an appeal with the Tax Tribunal.