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1. The Defendant’s imposition of KRW 38,070,00 (including additional taxes) of gift tax on Plaintiff B on December 11, 2014, 9,517.
Reasons
1. Details of the disposition;
A. The Plaintiffs, C, D, and E are the network F (Death on April 2, 2012, hereinafter “the deceased”) and G’s children.
B. On April 30, 2007, Plaintiff A borrowed KRW 500,000,00 from the Industrial Bank of Korea. At the time, the deceased provided the Industrial Bank of Korea, as a surety, with a surety of the Plaintiff A, as security, the land and the above ground buildings owned by the Bank of Korea (hereinafter “the instant real estate”). On May 7, 2007, the registration of the establishment of the instant real estate in the name of the debtor A, the maximum debt amount of KRW 600,000,000 was completed.
C. The instant real estate was sold in KRW 2,050,000 on August 28, 2007, and KRW 503,753,840, which was part of the purchase price, was used to repay the principal and interest obligation to the Plaintiff A Industrial Bank of Korea on March 25, 2008.
On the other hand, D brought a lawsuit against G and the Plaintiff at the Seoul Southern District Court on August 20, 2012, which was after the deceased died. During the lawsuit, the Plaintiff asserted that B received KRW 150,000,000 out of the purchase price of the instant real estate from the deceased.
E. Around June 2014, the Defendant: (a) performed an inheritance tax investigation on the Plaintiffs; (b) deemed that: (c) the amount of inheritance tax imposed on the Deceased; (d) the Plaintiff A was donated KRW 503,753,840 on March 25, 2008; and (e) the Plaintiff B was donated KRW 150,00,00 on March 26, 2008; and (e) on December 11, 2014, the amount of gift tax imposed on the Plaintiff A was KRW 373,963,421 (including additional tax); and (c) KRW 179,024,024 (including additional tax; (d) the amount of inheritance tax imposed on the Plaintiff A, including KRW 503,753,840, supra, within 10 years prior to the death of the Deceased; and (d) each disposition was imposed on KRW 1,710,097,3360 (including additional tax) and KRW 30757).7 (hereinafter referred to each of the Plaintiff.
(f).