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(영문) 서울고등법원 2011.05.12 2009누40034
법인세등부과처분취소
Text

1. The plaintiff's appeal against the defendants is dismissed in entirety.

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

purport, purport, and.

Reasons

1. The reasons for the court's explanation of this case are as follows: "Establishment of the second 15th of the judgment of the court of first instance" was followed: [The above investment shares with respect to B was later transferred to the transferee "as of the date of transfer" (hereinafter "as of the date of transfer") on the date of each transfer; the third 19 to 20, 5th 21, 5th 3, 7, 8th 7, 15th 7, 10, 11th 16th 16th 11, and 11th 2nd 8th 15th 2nd 2nd 2nd 2nd 2nd 3rd 2nd 2nd 3rd 2nd 4th 2nd 3rd 2nd 3rd 3rd 3rd 3rd 19, 46th 16th 16th 2nd 3rd 2nd 4th 2nd 3rd 2nd 4th 3rd 3rd 2nd 3rd 3rd 3rd 3rd 3rd 3rd .

2. Additional matters to be determined

A. The Plaintiff had already transferred the investment shares in B to another fund prior to the payment of the instant dividend income due to the operation and disposal of the instant building, and thus, there was no room for the instant dividend income to be substantially attributed to the said four divided partnerships, and therefore, the instant dividend income did not belong to the said four divided partnerships.

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