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1.The judgment of the first instance shall be modified as follows:
On August 14, 2012, the Defendant reverted to the Plaintiff (1) in 2009.
Reasons
1. Details of the disposition;
A. The director of the Seoul Regional Tax Office received KRW 10,472,514,080 (hereinafter “instant shares”) when he/she transferred the Plaintiff’s shares of the instant company 19,040 (hereinafter “instant shares”) to Myeono Young-young, from March 12, 2012 to June 30, 2012, and then notified the Defendant by deeming that he/she donated the instant shares in cash to the Plaintiff several times from that time to June 2012.
B. On August 10, 2012, the Defendant imposed and collected a total of KRW 2,470,712,40 (including additional taxes) on the two donated donations in the year 2012 on the basis of the Plaintiff, and imposed and collected a total of KRW 338,461,200 (including additional taxes) on the two donated donations in the year 2009 on August 14, 2012, the Defendant imposed and collected a total of KRW 853,507,500 (including additional taxes) and KRW 631,456,420 (including additional taxes) on the total of donated donations in the year 2010.
C. On November 9, 2012, the Plaintiff appealed to the Tax Tribunal, and filed a request for a tax trial on November 20, 2012, and the Tax Tribunal on November 20, 2014.
Of the total 23 donations, KRW 7,647,402,369, the sum of KRW 1,143,258,200, KRW 252,850,872, securities investment amounting to KRW 370,318,00, KRW 47,000, and KRW 1,813,427,072 (hereinafter referred to as “the sum of KRW 47,00,00,00, and KRW 1,813,427,07,00, and KRW 37,000,000, and KRW 23,00,000, and KRW 1,813,427,07,00 (hereinafter referred to as “the sum of this case”), the gift tax should be imposed on the remainder of the donations except for the purchase cost, marriage and wedding, and securities investment amount.
In accordance with the above decision of the Tax Tribunal on December 8, 2014, the Defendant: (a) against the Plaintiff on December 8, 2014, the sum of the gift tax on the instant money as indicated below and the instant apartment interior interior expenses, 73,728.