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1. The plaintiff's appeal is dismissed.
2. The costs of appeal shall be borne by the Plaintiff.
The purport of the claim and appeal is the purport of the appeal.
Reasons
1. Details of the disposition;
A. The Plaintiff is a certified public accountant, and the Plaintiff is a B accounting corporation (hereinafter “B”) from May 12, 2005 to July 1, 2008 (hereinafter “B”).
(2) Around June 30, 2008, the Plaintiff entered into an agreement with B on June 30, 2008, on the grounds that the Plaintiff had worked as a director.
Although the Plaintiff is disputing the meaning of set management, the Plaintiff agreed to receive KRW 1,313,00,000 for a total of five years under the pretext of “Set Management Amnet” from B, and KRW 80,418,000 for two years under the pretext of “Loss Red Cross”, as well as “Loss Red Cross”, in consideration of the prior meaning, the resignation of partnership, and the circumstances concluded in relation to retirement from the company; hereinafter “instant contract”).
3) B is the Plaintiff’s total of KRW 525,200,000 (hereinafter “instant settlement amount”) with the settlement amount for year 2009 and year 2010 as follows:
(2) A total of KRW 80,418,00 (hereinafter “instant damages reserve”) in 2009 and 2010 (hereinafter “instant damages reserve”).
section 262,600,000 of the original settlement amount 2009 262,600,000 2010 2010 262,600,000 of the compensation reserve 2009 40,209,00 2010 40,209,000
B. A disposition imposing global income tax 1) B determined that the instant settlement amount and the compensation reserve constituted other income as an honorarium, and did not deduct necessary expenses, withheld 20% of the amount paid as income tax, and submitted a payment record. (2) However, the Plaintiff deducted 80% of the pertinent amount from necessary expenses on the ground that the instant settlement amount constitutes the transfer cost of goodwill, and filed a comprehensive income tax return for the year 2009, by classifying the instant compensation reserve as dividend income.
3. On March 3, 2011, the Defendant: (a) on the ground that the instant settlement amount and the compensation reserve constituted other income as a honorarium; and (b) on March 3, 201, the global income tax on the Plaintiff for the year 2009.