District Court-2013-Gu Partnership-15205 ( October 02, 2014)

Whether the transfer of title to the shares of this case constitutes deemed donation of title trust

It is insufficient to find that the Plaintiff had no tax avoidance purpose at the time of title trust with respect to the instant shares Nos. 1 and 2, and that there was no tax avoidance purpose in the title trust.

Article 2 of the Inheritance Tax and Gift Tax Act

2014Nu47572 Revocation of Disposition of Imposition of Gift Tax

Note AA

AA Head of the Tax Office

on April 04, 2014

October 02, 2014

1. The plaintiff's claim is dismissed.

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

The judgment of the first instance shall be revoked. The disposition of imposition by the Defendant on October 10, 2012 against the Plaintiff on October 10, 2012 shall be revoked.

The reasons for the judgment of the court of first instance are reasonable, and thus, it is accepted on the grounds of this judgment in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act. (However, " September 5, 2012" shall be corrected as " October 10, 2012," "the second bottom of the judgment of the court of first instance" as " October 2012.") The plaintiff's appeal of the court