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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. From June 5, 2002, the Plaintiff is a company that has engaged in the luminous film manufacturing business of television, etc. from ethic City B.
B. In accordance with the resolution of the general meeting of shareholders and the board of directors, the Plaintiff paid to the executives of the Plaintiff company KRW 245,00,000 in bonuses, KRW 740,000 in 209, KRW 740,000 in 2010, and KRW 508,000 in 200 in total, KRW 1,493,000,000 in 201 (hereinafter “instant bonus”) and paid KRW 47,363,146 in 209 in which the Plaintiff invested 100% in the territory of the Republic of Korea (hereinafter “the instant bonus”), and dispatched the Plaintiff’s employees to C with labor expenses, and paid them to 47,363,146 in 209, KRW 82,583,168 in 20, KRW 105,613,085 in 201, and KRW 539,5399 (hereinafter “the instant bonus”).
C. From April 24, 2013 to June 22, 2013, the Central Regional Tax Office notified the Plaintiff of the result of the tax investigation on July 4, 2013 to the effect that: (a) the Plaintiff shall be deemed to have paid the instant bonus and personnel expenses without any grounds for payment; (b) the Plaintiff shall be deemed to have paid the instant bonus and personnel expenses, and (c) the Plaintiff shall be subject to rectification of corporate tax for the year 2009 to 2011.
On July 30, 2013, the Plaintiff filed a request for pre-assessment review with the Director of the Central Regional Tax Office on July 30, 2013, but the non-adopted decision was rendered on September 6, 2013.
E. On September 13, 2013, the Defendant notified the Plaintiff of the amount of corporate tax for the year 2009 as KRW 541,863,90, the corporate tax for the year 2010 as KRW 896,285,340, and the amount of corporate tax for the year 2011 as KRW 371,639,083, respectively.
F. On November 18, 2013, the Plaintiff appealed and filed a request for review with the Commissioner of the National Tax Service on November 18, 201, and the Commissioner of the National Tax Service, on March 4, 2014, the amount equivalent to the reduction in officer’s benefits (107,00,000 won) decided by the board of directors on July 29, 201, out of the instant bonus, deemed as compensation for benefits, was included in the deductible expenses, thereby correcting the corporate tax reverting to year 201
G. The defendant around April 2014 according to the result of the above request for examination.