Chuncheon District Court-2017-Gu Partnership-51981 ( November 13, 2018)

Global Income Detailed and Revocation of Disposition

(1) On the premise of an unlawful tax investigation, the plaintiff's assertion that each of the dispositions of this case was made in violation of the principle of prohibition of disadvantageous alteration under the Framework Act on National Taxes, ③ taxation requirement legal principle, strict interpretation principle, etc., ④ assertion that the principle of trust and good faith has been violated, and ④ assertion that the imposition of additional tax for unfaithful payment

The contents of the judgment are the same as attachment.

Article 80 of the Income Tax Act

(Chuncheon)2018Nu1423 global income and revocation of such disposition;

AA

BB Director of the Tax Office

on October 23, 2019

on October 20, 2019

1. The plaintiff's appeal is dismissed.

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

The judgment of the first instance shall be revoked. Each disposition of imposition of global income tax of KRW 246,587,036 (including additional taxes) and global income tax of KRW 244,814,647 (including additional taxes) for the year 2012 reverted to the Plaintiff on February 1, 2017 shall be revoked.

1. Quotation of judgment of the first instance;

The grounds for appeal by the plaintiff are not significantly different from the allegations in the first instance court, and according to the evidence duly adopted and examined by the first instance court, it is reasonable to find the facts in the first instance court and make a judgment, and it cannot be deemed that the judgment of the first instance court has the same errors as the plaintiff

Therefore, the reasoning of the judgment of the court is as stated in the reasoning of the judgment of the court of first instance. As such, it is acknowledged pursuant to Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act. [The plaintiff also asserted that the transfer of each real estate in 2011 and 2012 does not constitute "real estate sales business". The court submitted attached materials on December 28, 2018. However, in the related lawsuit, "the plaintiff was designated from 2004 to 2012 as the original city, the court frequently transferred 61 lots of land, such as cereal estate, and 6 buildings, such as cereal estate, which were located at 25 times and 24 times after the acquisition of each of the above real estate in order to purchase and sell the land at an appropriate time, and thus, it constitutes a lack of 201,261,2714,000's business income from each of the above real estate, and thus, it cannot be accepted.

2. Conclusion

Thus, the plaintiff's claim of this case shall be dismissed as it is without merit. The judgment of the court of first instance shall be dismissed.

The plaintiff's appeal is dismissed. It is so decided as per Disposition by the assent of all participating Justices.

shall be ruled.