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(영문) 서울행정법원 2011.04.21 2010구합15643
법인세등부과처분취소
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 director of the Seoul Regional Tax Office, from March 24, 2009 to April 20, 2009, conducted an integrated investigation into corporate tax from the year 2004 to the business year 2008 with respect to the Plaintiff from the pharmaceutical wholesaler to April 20, 209. The director of the Seoul Regional Tax Office included 240,480,938 won as of the end of the business year 2004 and 1,97,983,688 won for sales omitted in filing a report from the business year 2004 to the business year 2008, and notified the Defendant of the result of the tax investigation on the bonus disposal for the representative.

B. In accordance with the above notification, the Defendant imposed the Plaintiff (1) KRW 132,150,220 of corporate tax for the business year 2004, KRW 384,148,250 of corporate tax for the business year 2006, corporate tax for the business year 30,310,690 of corporate tax for the business year 2007, KRW 292,810,210 of corporate tax for the business year 2008, and KRW 37,569,940 of value-added tax for the business year 204, and KRW 2,238,464,626 of corporate tax for the business year 204 as the Plaintiff’s representative on July 6, 2009 (2), KRW 540,620, KRW 240 of corporate tax for the business year 2005, KRW 16,410,514,205, KRW 2307,3754,2075

C. On September 29, 2009, the Plaintiff filed a request for review with the Commissioner of the National Tax Service on September 29, 2009. On December 31, 2009, the Commissioner of the National Tax Service rendered a decision to re-examine the payment of KRW 240,480,938 of the converted amount of the stock omitted sales to the Defendant on December 31, 2009 to rectify corporate tax and value-added tax against the Plaintiff on the ground that there is no amount of KRW 240,480,938 of the converted amount of the stock omitted sales. On the other hand, the Plaintiff adjusted the difference between the credit sales sales sales amount sent by a pharmacist in 2008 and the credit sales amount calculated by the Plaintiff on the basis of the difference between the credit sales sales amount and the sales sales amount calculated by the Plaintiff.

After re-audit according to the above review decision, the director of the Seoul Regional Tax Office has conducted a re-audit on March 9, 2010, and the credit purchase amount and pharmaceutical affairs appropriated by the plaintiff in the business year 2008.

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