Seoul Administrative Court 2010Guhap8737 ( October 27, 2010)

Seocho 209west 1589 ( November 25, 2009)

If a person is a dual resident, income tax

In a foreign country, the rental income occurs in Korea and the place of residence is considered to be the resident of the most closely related contracting state in accordance with the tax treaty if the income is domestically and overseas.

The contents of the decision shall be the same as attached.

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1. The plaintiff's appeal is all dismissed.

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

The judgment of the first instance shall be revoked on December 12, 2008 by the defendant's request for reduction of the amount of 18,439,238 won in 205 to 48,724,85 won in 2006 to 55,517,008 won in 207 to revoke all the disposition rejecting the request for correction by the defendant.

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1. The reasoning of the court's explanation concerning this case is the same as the part of the reasoning of the judgment of the court of first instance, and thus, it shall be quoted in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Conclusion

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