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1. Of the judgment of the court of first instance, the part against the plaintiffs regarding the order to revoke below shall be revoked.
Defendant.
Reasons
1. Details of the disposition;
A. E Co., Ltd. (hereinafter “instant company”) changed its trade name in the “F Co., Ltd.” (hereinafter “F Co., Ltd.”) entered into a stock transfer agreement (hereinafter “instant agreement”) with the company that manufactures Aluminum wheelchairs, its parts, which is a shareholder at the time following the resolution of the board of directors on December 6, 200, with G (i.e., death) (i., death) and the Plaintiff, and B on December 21, 200 to pay the price for the instant shares issued by the instant company (G8,000 shares, Plaintiff A9, B27,297 shares) totaling KRW 44,909 shares (hereinafter “instant shares”) owned by the instant company (hereinafter “instant shares”).
B. On September 27, 2010, the instant company held a special general meeting of shareholders from 158,500 to 44,909 shares, i.e., the instant shares, to be retired without compensation, to reduce capital, and completed the registration of change of capital reduction on December 9, 2010 through procedures such as public announcement.
C. The director of the Central District Tax Office notified the Plaintiffs of the fact that the Plaintiff constitutes a constructive dividend under Article 17 (1) 3 of the Income Tax Act, considering that the difference between the price of the instant case and the acquisition price of the instant shares constitutes the constructive dividend under Article 17 (1) 3 of the Income Tax Act.
According to the above notification, on January 11, 2013, Defendant Sejong District Tax Office imposed imposition of KRW 562,782,82,820 on the aggregate of KRW 460,385,840, and KRW 102,396,980, and KRW 562,782, and820, and KRW 1,310,923,275, and KRW 294,63,015, total of KRW 1,605,56,290, and KRW 290,00,000, which were imposed on Plaintiff B around January 201, 2013.
(hereinafter referred to as "each of the dispositions of this case"). 【No dispute exists concerning the basis for recognition, entry in Gap's 1 through 5, 7, and Eul's 1 through 5 (including provisional numbers), and pleadings.