Seoul Administrative Court 2014Guhap53452 (Law No. 16, 2014)

Seocho 2013west 4087 (2014.04.02)

The amount of income disposition belonging to the year 2006 falls under the legislation of non-appealed class, which is, in principle, allowed to apply the exclusion period for imposition 10 years.

(1) With respect to the application of the exclusion period of imposition of income tax and corporate tax on the amount of income disposition, the exclusion period of imposition shall be limited to the portion that reverts to the year 2005 at the time of legislation, and the exclusion period of imposition of income tax and corporate tax shall be limited to the portion that belongs to the court of first instance, but since 2006, the portion that reverts to the court after the exclusion period of imposition shall not be limited at the time of legislation, it constitutes a

The exclusion period for national tax assessment under Article 26-2 of the Framework Act on National Taxes

2014Nu6320 Revocation of notice of change in income amount, etc.

○○ Co., Ltd.

○ Head of tax office

Seoul Administrative Court Decision 2014Guhap53452 decided December 16, 2014

2015.04.22

2015.05.20

1. All appeals filed by the plaintiff and the defendant are dismissed.

2. The costs of appeal shall be borne by each party.

1. Purport of claim

On September 3, 2013, the Defendant’s notice of change in income amount in Nos. 1 through 4 in annexed Table 1, which was issued against the Plaintiff shall be revoked.

2. Purport of appeal

A. The plaintiff

The part of the judgment of the court of first instance against the plaintiff shall be revoked. The defendant shall revoke the notification of change in the income amount in the No. 4 of the attached Table 1 that the defendant against the plaintiff on September 3, 2013.

B. Defendant

The part against the defendant in the judgment of the first instance shall be revoked, and the plaintiff's claim corresponding to the revoked part shall be dismissed.

1. Quotation of judgment of the first instance;

The reasoning of the judgment of the court is the same as that of the judgment of the court of first instance, and thus, it is accepted by Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act.

2. Conclusion

The judgment of the first instance is justifiable. All appeals by plaintiffs and defendants are dismissed.