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1. The Defendant’s imposition of global income tax of KRW 146,352,650 on January 2, 2012 against the Plaintiff on January 2, 2012, and KRW 20,90.
Reasons
1. Details of the disposition;
A. B Co., Ltd. (hereinafter “B”) was established on March 20, 200 for the purpose of wholesale business of computer peripheral devices, etc., and was voluntarily closed on May 31, 2007. The Plaintiff was appointed as the representative director of B on December 29, 2006 and entered on the corporate register on January 4, 2007.
B. From January 28, 2009 to February 17, 2009, the director of the tax office of thischeon District Tax Office conducted on-site verification B, and closed the business without collecting KRW 248,00,000 for shareholders' short-term claims stated in the settlement of accounts for the business year 2006. After the Plaintiff was appointed as the representative director B, 126,20,000 won was recovered, but the place of use of KRW 68,154,851 among them is unclear. After the Plaintiff was appointed as the representative director, the Plaintiff was selling KRW 20,00,000 to Taecheon-si Co., Ltd. around the beginning of 207, but without filing a corporate tax return thereon, the Plaintiff’s total amount of KRW 18,360,000,000 deducted from the total amount of KRW 1,640,000,000 for bonus income calculated under simple expense rate, and notified the Defendant of KRW 317,794,84,0081,008
C. On January 2, 2012, the Defendant determined and notified the Plaintiff of KRW 146,352,650 as global income tax for the year 2007.
(hereinafter “instant disposition”) D.
On July 30, 2012, the Plaintiff dissatisfied with the instant disposition, filed a request for review with the National Tax Service on July 30, 2012. On October 22, 2012, the Commissioner of the National Tax Service rendered a review of whether the Plaintiff received KRW 248,00,000 from the representative director before the Plaintiff was appointed as the representative director B, which was appropriated in the settlement of accounts in the business year 2006, to determine whether to impose global income tax.
E. According to the above review and determination, the Defendant’s short-term claim against D, the former representative director of B, from November 12, 2012 to December 23, 2012.