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1. The plaintiff's claims against the defendants are all dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
Reasons
1. Details of the disposition;
A. On July 28, 2006, the Plaintiff acquired each of the above ground new buildings (hereinafter collectively referred to as “instant real estate”) on June 1, 2007, and leased the instant real estate to Nonparty B, the largest shareholder of the Plaintiff on October 29, 2008.
B. From October 16, 2014 to December 5, 2014, the director of the Seoul Regional Tax Office conducted an integrated investigation of the Plaintiff’s regular corporate tax (hereinafter “instant tax investigation”) for the business year 2012 from October 16, 2014 to December 5, 2014; (1) on the premise that “the Plaintiff’s acquisition of the instant real estate is the same as the loan to B” as the purchase price of the real estate to be actually used by B”, the Plaintiff deemed the acquisition fund of the instant real estate as a provisional payment in charge of the business affairs related to B, and deemed the acquisition fund of the instant real estate as a wrongful calculation and recognized as a joint payment and notified the above head of the Seoul Regional Tax Office of the inclusion of the taxation data in deductible expenses.
C. Accordingly, on December 12, 2014, the head of the Seoul District Tax Office notified the Plaintiff of the rectification of KRW 35,780,883 and KRW 14,061,07 of corporate tax for the business year 2011, and KRW 28,47,596 of corporate tax for the business year 2012 and KRW 8,47,59,471 of corporate tax for the business year 2013 and KRW 5,09,229 of corporate tax for the business year 2013. On January 2, 2015, the head of the Seoul District Tax Office notified the Plaintiff of the rectification of KRW 137,463,582 of income for the business year 201, KRW 10,227,223, KRW 223, KRW 15,3721 of income for the business year 2013, respectively.
(hereinafter collectively referred to as “instant disposition”). D.
The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on July 14, 2015, upon filing an objection on March 13, 2015, but was dismissed on December 28, 2015.