Seoul Administrative Court-2016-Gu Partnership-84863 ( August 11, 2017)

Examination-corporation-2016-0022 (2016.09.09)

The date of provision of services under the tax invoice of this case constitutes the date of determination of the terms of payment of attorney fees.

In the process of the reinforcement investigation after the prosecution's non-detention, defense service was provided even during the process of the reinforcement investigation, and it is unclear whether the additional prosecution will be filed. Therefore, it cannot be deemed that the terms and conditions of the payment of contingent remuneration on the date of non-detention

Article 40(1) of the Corporate Tax Act

2017Nu68570 Revocation of notice of change in income amount

Law Firm ○

○ Head of tax office

Seoul Administrative Court Decision 2016Guhap84863 decided August 11, 2017

January 10, 2018

February 7, 2018

1. The plaintiff's appeal is dismissed.

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

The judgment of the first instance is revoked. The defendant's notification of the change in the income amount of 000 won for the year 2010 income to the plaintiff as KimA, which was made against the plaintiff on March 0, 2016 (referred to as " July 0, 2015," written in the written complaint of appeal, seems to be a clerical error) is revoked.

1. Quotation of judgment of the first instance;

The reasoning of this court's explanation concerning this case is as stated in the reasoning of the judgment of the court of first instance, in addition to the submission of part of the judgment of the court of first instance as follows. Thus, the grounds asserted by the plaintiff in this court are not significantly different from the contents of the judgment of the court of first instance, and the fact-finding and judgment of the court of first instance that rejected the plaintiff's assertion even if both the evidence submitted in the court of first instance and the evidence additionally submitted in this court are examined, this court's determination is justifiable).

Pursuant to the first sentence of the first sentence, the term " June 0, 2016" was " September 0, 2016," and the term "instant disposition" in the first sentence and the first sentence and the first fourth sentence were "the disposition of this case" as "the disposition of this case".

"At the time of appearance of counsel for the first instance court's "for the first instance court's first instance court's second instance', the "three times of attendance" as "four times of attendance", and the "No. 12" in the 6th instance court's second instance court's "No. 13" as "No. 13."

2. Conclusion

Therefore, the judgment of the first instance court is legitimate, and the plaintiff's appeal is dismissed as it is without merit. It is so decided as per Disposition.