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1. All of the plaintiffs' claims are dismissed.
2. The costs of lawsuit are assessed against the plaintiffs.
Reasons
1. Details of the disposition;
A. C Co., Ltd. (hereinafter “C”) is a corporation that was established on January 4, 2002 and operates an electronic commerce site, etc. for childcare goods, and its representative director is D. The Plaintiff B’s spouse, E’s partner, and F are the same as D’s interest relationship, and the shareholder change in C’s statement of the change of stocks, etc. are as follows.
As of the date of establishment of January 4, 2002 (share ratio) for 2006 business year (from January 1, 2006 to December 31, 2006), 201 business year (from January 1, 2011 to December 31, 2011) for acquisition (transfer) of shares on June 3, 2006 as of June 5, 2006 (share ratio), D 40,000 (40%) for 10,000, 200, 200, 200, 200, 300, 300, 300, 300, 300, 300, 300, 300, 300, 3000, 300, 300, 3000, 300, 300, 6300, 300 shares)
B. The director of the Central Regional Tax Office of China: (a) as a result of the consolidated investigation of corporate entrepreneurs from November 25, 2014 to January 28, 2015 with respect to C, the Plaintiff 30,000 shares of C acquired on June 3, 2006, and the same month.
5. Along with C’s total of 90,000 shares issued in addition to C’s capital increase with capital increase (hereinafter “instant shares”) confirmed that title trust was obtained from Plaintiff B, and notified the Defendant thereof.
C. The Defendant assessed the instant shares according to the supplementary assessment method (i.e., KRW 390,50,000, KRW 326,610,000) as the value of donated shares. On May 11, 2015, the Defendant issued a notice to the Plaintiff under Article 45-2 of the former Inheritance Tax and Gift Tax Act (amended by Act No. 8828, Dec. 31, 2007; hereinafter “former Inheritance Tax Act”) on the aggregate of KRW 330,161,690 (i.e., KRW 146,37,710, KRW 710 related to the acquisition by transfer on June 3, 2006) as the value of donated shares, and designated the Plaintiff’s joint and several payment notice as the date of June 5, 2006.
(hereinafter “each disposition of this case”) D.
The plaintiff is dissatisfied with this, and on January 2015.