Suwon District Court-2017-Gu Partnership-6298 ( November 14, 2017)

The time when the land was demolished prior to sale in deductible expenses;

The contract of this case is a sales contract for consignment, and the date of sale of land to a buyer who is not the date of delivery of land and a building on land shall be deemed the date of reversion of earnings. In the case of a building on land which was previously removed, it shall not be deemed that the time of reversion of losses should be deemed to be the time of removal of the land (the same as the

Article 40 of the Corporate Tax Act

2017Nu84534 Revocation of Disposition of Corporate Tax Imposition

A****

*The Director of the Tax Office

Suwon District Court Decision 2017Guhap62298 Decided November 14, 2017

March 22, 2018

April 5, 2018

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. On April 8, 2015, the Defendant revoked the imposition of KRW 50,475,380 of the corporate tax for the business year of 2011 against the Plaintiff and KRW 594,814,730 of the corporate tax for the business year of 2012.

1. cite of the reasons for the written judgment in the first instance;

The reasoning for this Court regarding this case is as stated in the reasoning of the judgment of the court of first instance, except as stated in Paragraph (2). Thus, this Court shall accept it in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Parts to be dried;

○ From the bottom of the reasoning of the judgment of the first instance, it is reasonable to see the instant contract as the consignment sales contract, and the part " it is reasonable to see that the instant contract is a contract to which the Plaintiff delegates authority for the conclusion of a contract or a sales contract to AA Construction."

The part of the judgment of the court of first instance, "the contract of this case is a contract for entrustment and purchase," which is "the contract of this case is a contract for entrustment and sale," is called "the granting of power of representation concerning the contract of this case."

3. Conclusion

Since the judgment of the first instance is justifiable, the plaintiff's appeal is dismissed as it is groundless.