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1.(a)
Defendant Sung Dong Tax Office’s Head of Sungdong Tax Office’s KRW 2,600,000 on February 5, 2013 for the gift tax of KRW 2,60,000 on February 5, 201;
(b) the defendant.
Reasons
1. Details of the disposition;
A. The director of the Seoul Regional Tax Office, from July 23, 2012 to September 5, 2012, conducted a stock change investigation with respect to E Co., Ltd. (hereinafter “E”) and stockholders, etc. of E (hereinafter “first tax investigation”), and on January 2, 2002, acquired by the Plaintiff A as of January 2, 2002 (the following (i.e., “stocks”; hereinafter the same shall apply) 2,00 shares of E acquired by the Plaintiff at the time of establishment of E
On January 2, 2002, the Plaintiff C deemed to have held title trust with the Plaintiff, and 1,000 E shares acquired by F (2,00 shares, hereinafter referred to as “instant 2 shares”) are the issues of this case.
(3) On January 2, 2002, Plaintiff C deemed to have held title trust with F, and Plaintiff D deemed to have held 1,000 shares of E acquired on February 2, 2004 (3 shares, hereinafter referred to as “instant three shares”).
) The Plaintiff C re-acquisitions the shares held in title by the Plaintiff C with the Plaintiff, and deemed that the Plaintiff C donated them to the Plaintiff D. The Plaintiff’s 1,000 shares of E acquired by the Plaintiff B on December 28, 2010 (4) shares of the following table, hereinafter “instant 4 shares”).
Plaintiff B deemed donated from F, and notified Plaintiff A of the result of the tax investigation to the effect that: (a) the gift tax of KRW 2,600,000 for the year 202; (b) the gift tax of KRW 125,959,743 for the year 2010 for Plaintiff B; and (c) the gift tax of KRW 4,356,027 for the year 2004 for Plaintiff D is scheduled to be imposed respectively;
hereinafter referred to as "pre-announcement of taxation of this case"
(2) On December 1, 2010, 200, 200 on December 1, 2011, 200, 300 G 3,000 G 3,000 G 3,000 3,000 3,000 Y 1,2,000 △△, 1,000 △△△△,000 △△, 1,000 △△, 1,000 △△△, 1,000 △△, 1,000 △△△, 00 △△△, 1,000 △△△△, 1,000 △△△△, 1,000 △△△△, 30, 1,000 △△△△△,00 1,000 △△△△,000 1,000 △△△△,01010 1000.
B. On September 28, 2012, Plaintiff A, B, and D asserted a pre-assessment review against the Director of the Seoul Regional Tax Office.