logobeta
본 영문본은 리걸엔진의 AI 번역 엔진으로 번역되었습니다. 수정이 필요한 부분이 있는 경우 피드백 부탁드립니다.
텍스트 조절
arrow
arrow
(영문) 수원지방법원 2013.08.22 2013구합322
종합소득세부과처분취소
Text

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. The Plaintiff is a real estate sales businessman who purchased land, such as the rice field development area in Echeon-si, Echeon-si, and Echeon-si, and sells it for the purpose of new construction site, including commercial buildings.

B. On June 3, 2009, on the trade name of “B,” the Plaintiff registered his/her name as the location of 1107, Gangnam-gu Seoul Metropolitan Government C building 1, and registered his/her business in his/her name as the location of the Seoul Gangnam-gu D building 90-9 on September 26, 2009.

C. In 2009, the Plaintiff reported the revenue amount of the business place under the Plaintiff’s name in KRW 2,49,355,848, and necessary expenses to KRW 2,363,909,379 (including sales promotion expenses, KRW 880,94,819). The Plaintiff reported the revenue amount of the business place under the Plaintiff’s name in KRW 2,148,736,670, and necessary expenses to KRW 2,041,69,951 (including KRW 649,865,91), and reported the revenue amount of the business place under the Plaintiff’s name in KRW 6,003,189,455, and necessary expenses to KRW 6,004,00,000,574 (including sales promotion expenses, KRW 2,530,785,583), and reported the revenue amount of the business place under the Plaintiff’s name to KRW 3,756,196,37565

As a result of the investigation conducted by the Defendant on the above reported details, the Plaintiff’s global income amount was corrected to the amount included in the income amount of the business place under the name of the E, and the Plaintiff’s global income amount was denied, and sales promotion expenses in 2009 were corrected to KRW 1,465,67,314, and sales promotion expenses in 2010 were corrected to KRW 2,310,643,375.

On April 24, 2012, the Defendant imposed upon the Plaintiff the global income tax of KRW 593,524,510, and KRW 2,818,916,580 (the amount to be reduced to KRW 2,613,07,464) for the global income tax of KRW 2009 (the amount to be reduced to KRW 2,613,07,464) according to the amount of tax calculated under Article 64(1)2 of the Income Tax Act (in calculating the profit margin on real estate, the sales promotion expenses shall not be deemed necessary expenses of the transferred asset).

(hereinafter “instant disposition”) e.

The Plaintiff is dissatisfied with the instant disposition and on July 2012.

arrow