No co-inheritors may be deemed to have transferred the inherited real estate share to one of them.

In accordance with the agreement on the division of inherited property between co-inheritors, only one of the co-inheritors was reverted to the sole ownership of one of the co-inheritors, as retroactively from the date of commencing the inheritance due to the agreement on the division of inherited property between them, and the other co-inheritors

Article 88 (1) of the Income Tax Act

Revocation of a disposition imposing capital gains tax, etc. by the Seoul Administrative Court 2018Guhap89268

○○ Kim and five others

AA Head of tax office and 3

2019.19

October 29, 2019

1.

A. On December 1, 2017, the part of the imposition of capital gains tax of KRW 529,069,280 (including additional tax) imposed by Defendant AA head of the tax office on Plaintiff Kim○○ on December 1, 2017 and the imposition of KRW 104,740,950 (including additional tax) of global income tax of KRW 1,937,245, additional tax of KRW 1,08,766;

B. Defendant BB director of the tax office on December 1, 2017

1) Of the imposition of the global income tax of KRW 529,115,480 (including additional tax) and the imposition of the global income tax of KRW 101,696,990 (including additional tax), the portion exceeding the global income tax of KRW 1,284,734 and the additional tax of KRW 743,421;

2) Of the imposition of capital gains tax of KRW 498,740,360 (including additional tax) and the imposition of global income tax of KRW 92,724,130 (including additional tax), the portion exceeding KRW 1,023,968, and additional tax of KRW 669,629, among the imposition of global income tax of KRW 92,724,130 (including additional

C. On December 1, 2017, the head of the DefendantCC’s tax office imposed capital gains tax of KRW 533,750,640 (including additional taxes) and imposition of global income tax of KRW 94,414,710 (including additional taxes);

D. Defendant DD Head of the tax office on December 1, 2017

1) Of the imposition of capital gains tax of KRW 529,244,740 (including additional tax) and the imposition of global income tax of KRW 106,726,810 (including additional tax), the portion exceeding KRW 984,606 and additional tax of KRW 224,830;

2) Of the imposition disposition of capital gains tax of KRW 529,096,540 (including additional tax) against Plaintiff Kim and the imposition disposition of KRW 107,093,340 (including additional tax), the portion exceeding KRW 2,297,61 and additional tax of KRW 1,277,67

Each cancellation shall be revoked.

2. Each of the plaintiffs' remaining claims is dismissed.

3. 1/10 of the costs of lawsuit shall be borne by the Plaintiffs, and the remainder by the Defendants, respectively.

Cheong-gu Office

The head of a tax office on December 1, 2017: (a) imposed a transfer income tax of KRW 529,069,280 (including additional taxes); (b) imposed a global income tax of KRW 104,740,950 (including additional taxes); (c) imposed a transfer income tax of KRW 529,115,480 (including additional taxes); (d) imposed a transfer income tax of KRW 529,115,480 (including additional taxes); (d) imposed a transfer income tax of KRW 101,69,990 (including additional taxes); (e) imposed a transfer income tax of KRW 498,740,360 (including additional taxes); and (e) imposed a transfer income tax of KRW 92,724,130 (including additional taxes); (e) imposed a transfer income tax of KRW 50,740 (including additional taxes); and (e) imposed a imposition disposition of KRW 209,741,7941,7970 (including additional tax); (30) imposed a transfer income tax of KRW 2940.7.7

1. Details of the disposition;

A. Inheritance relationship following the death of deceased Kim

1) On February 27, 200, the deceased Kim (hereinafter referred to as "the deceased") died on February 27, 200. The deceased co-inheritors jointly succeeded to the deceased (hereinafter referred to as "the co-inheritors of this case"). The deceased's family members are as follows: the deceased's spouse, son Kim △△△, the south Kim, the son Kim △△, the 3 South, the 4 South, the 4 South, the plaintiff Kim Kim Kim, the female, the deceased Kim ○, the 3rd, the female, and the deceased.

(F) such forest:

2) As inherited property of the deceased, there are land and buildings on ○○○○○○○-dong ○○○○○○○-dong 1, 2, 3, 4, and its ground (hereinafter referred to as “the bowling site site and buildings”) and land and buildings on 12, such as the same land and buildings (hereinafter referred to as “the warehouse site and buildings of this case”) and buildings on the same ground.

(b) Agreement on inherited property;

1) On August 5, 200, the co-inheritors of this case prepared a written agreement on August 5, 200 (hereinafter “the agreement of August 5, 200”) with Plaintiff Kim △△△△△ in the presence of the Plaintiff Kim △△△△, and the Plaintiff, Kim, Kim, Kim ○, Kim Kim Kim, Kim Kim Kim, Kim Kim, Kim Kim, Kim Kim, Kim Jong-young, and Kim Kim signed the said agreement, and the part related to the instant real estate is as follows.

【Agreement of August 5, 2000 of this case】

3. In principle, the site and the building of the instant bowling site shall be paid in installments to the six-type agents, including 1.3 billion won in base by agreement between the Deceased and Kim on June 23, 1999, the expected amount of gift tax of KRW 1.7 billion in the annual rent of KRW 1.6 billion in the annual rent of KRW 1.6 billion in the annual rent of KRW 1.6 billion in the annual rent of KRW, but the period shall be immediately paid at the time of sale of real estate (the real estate of paragraphs 1 and 2 above).

5. 이 사건 창고 부지 및 건물과, ○○ ○○구 ○○동 13 대지 및 위 지상 근린생활시설은 김▼▼(김의 처)에게 사인증여키로 한다.

2) On August 5, 2000, the remaining co-inheritors except Kim, expressed complaints regarding the instant agreement, and on August 19, 2000, on the following again, on August 19, 2000, the following agreements (hereinafter referred to as the “instant agreement”) were made, and the parts related to the instant real estate among them are as follows.

[Written Agreement of August 19, 2000]

1. In registering and reporting inheritance of the deceased’s remaining property within August 25, 2000, all matters shall be used only for legal submission and agree as follows:

2. On August 5, 200, the agreed terms have been fundamentally invalidated and detailed in detail have to be subsequently agreed.

3. ○○○-si ○○○○○○○-si ○○○○○○○○, 2, 3, 04, 5, 6, 7, and 10, and the site and buildings of the instant bowling site, the warehouse site and buildings of this case, and ○○-dong 13, ○○-gu, ○○○-dong, regardless of the transfer of legal ownership, should be jointly distributed and settled with the Plaintiffs 7.

10. The amount of KRW 1.3 billion and the amount of inheritance tax paid and other taxes not based on the agreement on June 23, 1999 by the Deceased and Kim shall be settled later and calculated by applying their respective interest rates to Kim and Kim.

11. The discussions from paragraphs 1 to 10 and matters other than those agreed upon shall be discussed later.

3) On August 23, 200, Kim Jong-soo prepared a written agreement on the division of inherited property (hereinafter referred to as "the agreement of August 23, 2000"), the content of which is such as the sole inheritance of Kim, except the remaining land of ○○○○-dong, 3, among the instant real property, on August 23, 200, and each co-inheritors of this case affixed their seals on the written agreement.

C. Registration of ownership transfer concerning the instant real estate

In accordance with the agreement of August 23, 200 of this case, Kim Jong-soo completed the registration of ownership transfer in the name of Kim on the ground of inheritance by agreement and division as of February 27, 2000 as to the warehouse site and building of this case on August 23, 200, except the land of ○○○○○-dong 3, 000, among the instant bowling book and building (as to the land of ○○○○○-dong 3, the registration of ownership transfer in the name of Kim-dong was completed on December 30, 199).

D. Progress of litigation related to the real estate of this case

1) Plaintiffs Kim, Kim, Kim, Kim○, and Kim Jong-chul

A) Notwithstanding the agreement that Kim, Kim, Kim, Kim, Kim, Kim, and Kim Jong-tae agreed on August 19, 200 to distribute the proceeds from the sale of the instant real estate to the co-inheritors of this case, on the ground that the sale of the instant real estate did not intend to sell and distribute the instant real estate without the consent of co-inheritors, thereby hindering the fulfillment of conditions under the said agreement, or that the said agreement would have been deemed to have arrived at the expiration of the time limit, the Plaintiff Kim, Kim, Kim, Kim, Kim, and Kim Jong-tae filed a lawsuit against Kim for the payment of the agreed amount of KRW 2 billion for each share of KRW 1/7 of the market price of the instant real estate as of January 20, 200 and damages for delay (Seoul Central District Court 2008Ga*).

B) On August 27, 2009, the above court accepted the claim of the above plaintiffs, and rendered a ruling that "Glaver shall pay 2,00,000,000,000 won to plaintiffs Kim, Kim, Kim, Kim ○, and Kim Jong-tae, and 20% interest per annum from January 24, 2009 to August 27, 2009, and 5% interest per annum from the next day to the day of full payment." This judgment appealed against this judgment, but the above court dismissed the appeal of Kim on September 30, 2010.

C) On February 23, 2012, the Supreme Court appealed Kim (Supreme Court 2010Da*). Article 3 of the Agreement on August 19, 200 as of February 23, 2012, the Supreme Court decided the joint obligation and requirements for the sale price of the real estate in this case. Paragraph (10) of the above Agreement provides that the amount paid by Kim under the agreement as of June 23, 1999 and the inheritance tax, etc. corresponding to the joint distribution under paragraph (3) shall be settled and settled. Thus, the court below rejected the claim for deduction or offset by Kim on the ground that there is no specific settlement agreement under paragraph (10) of the above Agreement between the above plaintiffs and Kim yet, on the ground that there was an error of law by misunderstanding the legal principles on the interpretation of the disposal document and thereby failing to exhaust all necessary deliberation, and reversed the judgment of the court below and remanded it.

D) After the first instance court (Seoul High Court 2012Na*) determined that Kim is obligated to pay the above plaintiffs the amount deducting inheritance tax, acquisition tax, and other expenses from the market value of 1/7 equity interest in January 2009 at the market value of 2,245,887,642. On August 30, 2012, the first instance court partially cancelled the judgment and subsequently dismissed the judgment of 1,534,112,879 won to the plaintiff Kim, and 1,534,531,562,62, and 692 won to the plaintiff Kim ○, and 1,534,562, and 1,533,787,498 won from November 20 to December 30, 2012, the Supreme Court dismissed the judgment of 200 per annum 140% from the next day to the 201.

2) Plaintiff Kim △△△

A) Plaintiff Kim △△△ also filed a lawsuit against Nonparty 1 claiming the payment of the agreed amount of KRW 2,245,887,642, which is the 1/7 equity interest in the market price of the instant real estate as of January 209 (Seoul Central District Court 2009Gahap*) and damages for delay thereof (Seoul Central District Court 2009Gahap*). On December 23, 2010, the said court rendered a judgment that “Gresh paid to the Plaintiff 2,245,887,642 won and the amount at the rate of KRW 20% per annum from September 8, 2009 to the day of full payment.”

B) Accordingly, Kim Jong-chul appealed (Seoul High Court 2011Na**). The above court rendered a judgment to the effect that, on January 20, 2009, Kim △△△, Kim is obligated to pay inheritance tax, acquisition tax, and other expenses after deducting the amount from the market value of 1/7 equity interest in the market value of 2,245,887,642, and that part of the judgment of the first instance was revoked, and that, on November 10, 2009 to August 30, 2012, "Seoul High Court 201Na678,548, and this part of the judgment was dismissed by the Supreme Court 1,372,678, and this part of the judgment of the first instance." The appeal was dismissed by the Supreme Court on December 11, 2014.

3) Plaintiffs Kim Jong-chul

A) While claiming as above 1-A of the real estate of this case, Plaintiff Kim Jong-chul also filed a lawsuit against Kim Jong-chul for the payment of the agreed amount of KRW 2,245,887,642, which is the 1/7 share of the market price of the real estate of this case on January 20, 209 (Seoul Central District Court 2009Gahap*) and damages for delay thereof (Seoul Central District Court 2009Gahap*). The above court determined that Kim Jong-tae is liable for the payment of the deducted amount of inheritance tax, acquisition tax, and other expenses to the Plaintiff Kim Jong-tae, which is the 2,245,887,642, which is the 1/7 share of the market price of the real estate of this case from January 20, 2009, the above court made a decision of 1,585,846,728 won and 1,585,75,2220 per annum from May 13 to 2014, 2014.

B) Accordingly, Plaintiff Kim Young-chul and Kim Jong-chul appealed (Seoul High Court 2011Na*), the above court judged that the increased value arising from the extension of the warehouse of this case should be additionally deducted, and partly revoked the judgment of the court of the first instance. The judgment of the court of first instance rendered a judgment that “Seoul shall be paid 5% per annum from May 13, 2010 to August 30, 2012, and 20% per annum from the next day to the day of full payment,” and that “Seoul shall be paid 5% per annum from May 13, 2010 to August 30, 2012, and 20% per annum from the next day to the day of full payment” (Supreme Court 2012Da*), but the Supreme Court appealed appealed appealed dismissed on December 11, 2014, and the above judgment became final and conclusive (hereinafter referred to as “each of the above plaintiffs’ civil cases”, and each of the above final judgment becomes final and conclusive.

E. Payment of money to the plaintiffs of Kim Kim

The plaintiffs received from Kim on September 12, 2012 the sum of the principal and damages for delay in accordance with the relevant judgment of this case (hereinafter referred to as "the agreement amount of this case", "the principal of this case", "the principal of this case", "the damages for delay in the final and conclusive judgment of this case", "the damages for delay in this case", and "the sum of the principal and damages for delay in this case" as stated below).

The real estate of this case

1/7 Equity (won)(A)

Inheritance Tax and other matters

cost(B)

Principal (original)

(C =A-B)

Damages for delay (won)

(D)

Principal and Damages for Delay

Total (C+D)

○ Kim

2,245,887,642

711,304,980

1,534,582,662

26,024,418

1,760,607,080

Kim

2,245,887,642

711,774,763

1,534,112,879

25,955,224

1,760,068,103

Kim

2,245,887,642

714,324,950

1,531,562,692

25,579,615

1,757,142,307

Gyeong Kim

2,245,887,642

712,100,144

1,533,787,498

26,024,418

1,760,607,080

Kim △△△

2,245,887,642

873,209,094

1,372,678,548

202,365,534

1,575,044,082

개지 Kim

2,245,887,642

671,078,353

1,574,809,289

192,428,752

1,767,238,041

F. Disposition of transfer income tax and global income tax in this case

1) As a result of conducting a tax investigation with respect to the Plaintiffs from October 5, 2016 to July 3, 2017, the EE regional tax office: (a) found that the Plaintiffs inherited 1/7 shares of the instant real estate in accordance with the agreement dated August 19, 200 and transferred the said shares to Kim, and received the payment for the said transfer; (b) deemed that the instant delayed payment constitutes subject to capital gains tax because it constitutes a taxable object of capital gains tax because it constitutes a compensation for breach or termination of a contract, which is the compensation received as a breach or termination of a contract, and thus constitutes other income, and thus, the Plaintiffs notified the Plaintiffs of the prior notice of capital gains tax and global income tax assessment with such content.

2) On August 30, 2017, the Plaintiffs filed a request for pre-assessment review with the Commissioner of the National Tax Service on August 30, 2017, and the Commissioner of the National Tax Service, on November 3, 2017, deducted KRW 10,356,107 from the agreed amount, the increased value arising from the extension of the warehouse of the instant case, and partially adopted the Plaintiffs’ claim that partially deducts KRW 30,778,929 from

3) On December 1, 2017, Defendant AA head of the tax office imposed capital gains tax of KRW 529,069,280 (including additional tax); adjusted the tax amount of KRW 104,740,950 (including additional tax); imposition of capital gains tax of KRW 529,115,480 (including additional tax); imposition of capital gains tax of KRW 529,696,90 (including additional tax); imposition of global income tax of KRW 101,69,90 (including additional tax); imposition of capital gains tax of KRW 498,740,360 (including additional tax); imposition of capital gains tax of KRW 92,724,130 (including additional tax); imposition of capital gains tax of KRW 53,750,640 (including additional tax); imposition of capital gains tax of KRW 50,740 (including additional tax); imposition of capital gains tax of KRW 97,9740 (including additional tax); imposition of capital gains tax of KRW 50,97140 (including additional tax); imposition of capital gains tax; imposition of KRW 97.4147).

2. The parties' assertion

The Defendants asserted that the disposition of this case and the disposition of global income tax are lawful on the grounds of the grounds of the disposition and the relevant statutes, and the Plaintiffs asserted that each of the above dispositions is unlawful on the following grounds:

A. The imposition disposition of capital gains tax of this case

1) In the agreement on August 19, 2000, the plaintiffs inherited the real estate of this case by the agreement on the division of inherited property, but in the case of selling the real estate of this case, the sale price was distributed to the plaintiffs, and in the case of not selling the real estate, the plaintiffs merely agreed to pay the amount equivalent to the value of the plaintiffs' share in the inheritance, and it cannot be deemed that the plaintiffs succeeded to the share in the real estate of this case and then transferred it to Kim. Therefore, the disposition imposing the transfer income tax of this case on the premise that the

2) Even if the transfer income tax can be imposed on the Plaintiffs regarding the instant agreed amount, as long as the Plaintiffs were to have the right to receive the instant agreed amount under the agreement on the division of inherited property with Kim, in the relevant judgment of this case, so long as the Plaintiffs determined the instant agreed amount as the price for transfer by the co-ownership transfer of real estate in this case, and thus, it is difficult for the Plaintiffs to report and pay the transfer income tax. As such, there is justifiable reason for failure to report and pay the transfer income tax, the additional tax amount in the

B. The instant global income tax imposition disposition portion

1) In order to receive the damages for delay in the instant case, the Plaintiffs paid the litigation costs in the instant case. As such, the costs of Plaintiff Kim○○○, KRW 210,696,700, KRW 210,637,482, and KRW 215,575, Plaintiff Kim Jong-tae’s litigation costs, KRW 210,575, and KRW 210,596,349, Plaintiff Kim Young-tae’s litigation costs, KRW 186,239,078, and KRW 197,50,760, and KRW 197,50,760 of the costs of the instant damages for delay in the global income tax base for the damages for delay in

2) Even if it is possible to impose a comprehensive income tax on the Plaintiffs on the instant damages for delay, if the instant contract amount is not capital gains, then the said litigation expenses were deducted from other income, and the Plaintiffs determined that there would be no remaining amount when deducting the above litigation expenses from the damages for delay, and did not return and pay the comprehensive income tax. As such, the Plaintiffs’ justifiable grounds for not paying the comprehensive income tax are recognized as to the failure of the Plaintiffs to return and pay the global income tax, and at least the penalty tax amount in the disposition

3. Relevant statutes;

It is as shown in the attached Form.

4. Determination

A. Whether the disposition of transfer income tax of this case is legitimate

1) The main sentence of Article 88(1) of the former Income Tax Act (amended by Act No. 12852, Dec. 23, 2014; hereinafter the same) defines transfer in capital gains tax as “an actual transfer of an asset at cost due to sale, exchange, investment in kind in a corporation, etc., regardless of the registration or enrollment of the asset”.

Meanwhile, an inheritor shall succeed to the rights and obligations of the inheritee as to the property of the inheritee from the time of commencement of inheritance (Article 1005 of the Civil Act). If there are several inheritors, the inherited property shall be jointly owned (Article 1006 of the Civil Act). If an inheritor does not determine the method of division of inherited property by his/her will, then the inheritor may divide the inherited property at any time (Articles 1012 and 1013 of the Civil Act). The effect of division shall accrue retroactively from the time of commencement of inheritance (main sentence of Article 1015 of the Civil Act). Of inherited property subject to division, there is no special limitation on the method of division of inherited property. Among inherited property subject to division, a specific inherited property is owned by one inheritor, and the inherited property may be divided by way of division, in cash, between the specific inherited property and the value of the specific inherited property at the time of commencement of inheritance. An inheritor who divided such specific inherited property shall be deemed to have been retroactively owned by another co-inheritors at the time of commencement of inheritance (see, e. 21, etc.271, supra).

2) In light of the above legal principles, the disposition of transfer income tax of this case is based on the premise that the plaintiffs acquired 1/7 shares of this case on the ground of inheritance, etc. The above 1/7 shares of this case were transferred to Kim, i.e., the following facts acknowledged: ① the agreement of August 19, 200 and the agreement of August 23, 200, the ownership of the real estate of this case should be reverted to Kim, 1/7 shares of this case on the ground that the above 1/7 shares were not acquired on the ground that the above 1/7 shares were not acquired on the ground of inheritance, but on the premise that the above 1/7 shares were not acquired on the ground that the above 1/7 shares were transferred on the ground that the above 2/10 shares were not acquired on the ground that the above 1/3 shares were acquired on the ground of inheritance, and thus, the purport of the judgment that the above agreement was invalid on the ground that the above 2/10 shares on the inherited property was not accepted on the ground that the inheritance agreement of this case.

B. Whether the instant disposition of global income tax was lawful

1) Determination on the assertion that litigation costs should be included in necessary expenses

A) The instant damages for delay constitute “other income” as “the penalty or compensation received due to a breach or termination of a contract under Article 21(1)10 of the former Income Tax Act.” However, Article 37(1)2 of the former Income Tax Act provides that “the total amount of expenses corresponding to the total amount of deposits in the relevant taxable period, which is generally accepted, shall be included in necessary expenses.”

B) In the litigation of the instant case, the fact that the litigation cost of the instant case was included in the total necessary expenses in the calculation of the tax base of the disposition imposing the transfer income tax of this case is either dispute between the parties, or that the litigation cost of the instant case was included in the total necessary expenses in the calculation of the tax base of the disposition imposing the transfer income tax of this case, and that the whole purport of the pleadings was considered as follows: (a) there is no dispute between the parties, (b) there is no evidence between the parties, (c) No. 210,637,482, (d) Plaintiff Kim Young-soo, and (e) No. 210,315,575 won, and (e) Plaintiff Kim Young-si, Kim Jong-tae, 210,596,349 won, and (e) Plaintiff Kim Jong-△, Kim △△△△, and KRW 186,239,078.

However, it is not recognized that "transfer of assets subject to taxation of transfer income tax of this case" is not an "transfer of assets subject to taxation of this case", and thus, the litigation cost of this case is the expenses paid in connection with the process of the related lawsuit, which caused damages for delay of this case, and constitutes expenses directly related to the occurrence of damages for delay of this case. Therefore, as long as the litigation cost of this case cannot be counted as necessary expenses in calculating the tax base of transfer income tax on the real estate of this case of the plaintiffs, it should be counted as necessary expenses in calculating the tax base of global income tax for the tax year 2012 pursuant to Article 37 (1) 2 of the former Income Tax Act

2) Determination as to the assertion that “justifiable cause” of exemption from penalty is recognized

A) Under a statutory provision that serves as the basis for imposing additional taxes, where a taxpayer is not obligated to pay the principal tax on the premise that the amount of principal tax becomes effective and conclusive, where a taxpayer is not obligated to pay the tax base and amount by the statutory deadline, additional taxes for non-declaration, underreporting, and insincere payment, which require the taxpayer to report and pay the tax base and amount within the statutory deadline (see, e.g., Supreme Court Decision 2015Du52616, Feb. 14, 2019). Meanwhile, Article 48(1) of the former Framework Act on National Taxes provides that penalty taxes shall not be imposed if a taxpayer has justifiable grounds for non-performance of his/her obligation. In order to facilitate the exercise of the right to taxation and the realization of a tax claim, where a taxpayer violates the law without justifiable grounds, administrative sanctions imposed as prescribed by the Act are not considered, and the taxpayer’s intention and negligence cannot be deemed as having been considered, and the land or mistake of the law does not constitute a justifiable reason (see, e.g., Supreme Court Decision 2013Du13).

B) Of the additional tax imposed on global income tax in this case, the portion corresponding to the principal tax that should be reduced according to deducting necessary expenses equivalent to the cost of lawsuit from the tax base on global income as seen in the foregoing paragraph (1) should be revoked as a matter of course. However, as seen in the table in paragraph (3) above, in the case of the plaintiffs other than the plaintiff Kim Jong-chul, even if the principal tax on global income is determined by deducting necessary expenses, it is obvious in calculating that there is the remaining difference. As alleged by the plaintiffs, even if the damages for delay in this case are believed to have no remaining amount upon deducting the litigation cost of this case from the damages for delay, and the comprehensive income tax was not paid, it is merely due to an error in the calculation, and thus, it cannot be deemed that there is a justifiable reason for the plaintiffs to have failed to file and pay the comprehensive income tax on the above difference

(iii)the calculation of a reasonable amount of tax;

On the premise that the instant litigation cost is included in the necessary expenses of the global income tax for the year 2012, the Plaintiffs’ total income tax attributed to the year 2012 is determined as indicated in the following table. Of the disposition imposing global income tax in this case, the portion exceeding the difference below and the additional tax should be revoked as it is unlawful.

Amount of legitimate tax;

Reported tax amount (won)

Difference (won)

Additional tax (won)

Difference + Total amount of additional tax (won)

AA Head of the Tax Office

○ Kim

2,320,225

382,980

1,937,245

1,088,766

3,026,011

BB Director of the Tax Office

Gyeong Kim

1,321,050

36,316

1,284,734

743,421

2,028,155

Kim △△△

1,023,968

0

1,023,968

69,629

1,693,597

CC director of the tax office

개지 Kim

16,031,485

16,031,485

0

0

0

D Head of the tax office

Kim

984,606

0

984,606

24,830

1,209,436

Kim

3,207,237

909,576

2,297,661

1,277,677

3,575,338

5. Conclusion

Therefore, the plaintiffs' claims against the defendants are reasonable within the scope of the above recognition, and each of the remaining claims is without merit, and it is dismissed. It is so decided as per Disposition.