Suwon District Court-2015-Gu Partnership-61413 (Law No. 14, 2016)

It is difficult to regard the value of the instant transaction as the market price of the instant shares.

Since it is difficult to view the value of the instant transaction as the market price of shares, and it cannot be deemed that the market price was clear at the time of the instant transaction, the instant disposition, which the Defendant calculated based on the complementary assessment method under the Inheritance Tax and Gift Tax Act

Article 52 of the former Corporate Tax Act rejection of Wrongful Calculation

2016Nu35160 Revocation of Disposition of Imposing corporate tax, etc.

주식회사 QQ

○ Head of tax office

Suwon District Court Decision 2015Guhap61413 Decided January 14, 2016

2016.09.09

October 14, 2016

1. The plaintiff's appeal is dismissed.

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

The judgment of the first instance court is revoked. On November 1, 2013, the defendant imposed corporate tax of 2010 on the plaintiff for the 2010 taxable year against the plaintiff and revoked the notice of change in income amount of 38,740,000 won for the income amount of 2010 taxable year for the 2010 income amount of 38,740,000 income amount of 101,072,400 won, above 194, 194,370,000 won, and ○○○○ 93,297,600 won for the 2010 taxable year against the plaintiff.

1. Quotation of the reasons for the judgment of the first instance;

This decision is identical to the reasoning of the judgment of the court of first instance, and therefore, Article 8(2) of the Administrative Litigation Act, the Civil Procedure Act

It shall be quoted by the main sentence of Article 420 as it is.

2. Conclusion

Therefore, the plaintiff's claim shall be dismissed as it is without merit, and the judgment of the court of first instance shall be just and the plaintiff's appeal shall be dismissed as it is without merit. It is so decided as per Disposition.