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(영문) 서울고등법원 2014.10.16 2012누15465
법인세부과처분취소
Text

1. The defendant's appeal is dismissed.

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

Purport of claim and appeal

1..

Reasons

1. The reasoning of the judgment of the court of first instance cited by the court of first instance is as follows, and thus, it is consistent with the reasoning of the judgment of the court of first instance, and thus, by Article 8(2) of the Administrative Litigation Act and the text of Article 420

In addition, the part written by the Court " shall be equivalent, and even if not, it shall be the same as that of merger in economic substance."

Part 6. The following shall be added to the sixth:

on June 16, 2003, VI and CT concluded a settlement agreement and plan stating that "VI approves voluntary dissolution and liquidation of CT and agrees thereto, and CT shall, as soon as possible, simultaneously with the complete retirement of its shares, transfer and distribute all assets, liabilities, rights, and obligations to VI to VI." "No. 20 No. 1 and No. 20 of A" in Part 7 of Section 6 of the 7th page is "No. 20, No. 22".

Part 1 to 6 of the 8th parallel 10 pages are as follows.

2) In light of the following circumstances, the aforementioned recognition and the court’s evaluation commission with respect to the Mayor of Seoul University Law School (Expert A professor) and the Head of Seoul University Law School (Expert B) shall be based on the overall purport of the arguments, and when calculating the value of the stocks at the time of the instant capital reduction, the average of the net profit and loss of VI and CT for three years before the date of the capital reduction shall be calculated by adding up the amount of net profit and loss of VI for three years before the date of the instant capital reduction. As such, in calculating the value of VI’s capital reduction, the instant capital reduction conducted for USD 50 per share cannot be deemed to constitute an wrongful calculation. Accordingly, the instant disposition should be revoked on a different premise. Since VI is a 100% parent company of the Seoul University, and the United States deelawa Corporation Act is prepared a certificate on the resolution of stock ownership and merger in lieu of preparation of the merger contract under Article 253 of the Corporate Act.

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