Seoul Administrative Court-2018-Gu Partnership-5048 ( October 11, 2019)

It is merely an act of simple administrative affairs that the tax authority grants temporary payment in annual installments at the request of the taxpayer.

Even if the tax authority grants a lump-sum payment permission upon the request of the taxpayer, it is difficult to deem that there was a new taxation at that time, and delivery of the written notice for voluntary payment is merely a simple administrative act to promote the convenience of the taxpayer, and it cannot be deemed a separate

Article 69 of the Enforcement Decree of the Inheritance and Gift Tax Act

2019Nu3349 Disposition of revocation of payment by annual installments.

O KimO

Head of the tax office;

April 4, 2019

April 25, 2019

1. The plaintiff's appeal is dismissed.

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

Cheong-gu Office

The judgment of the first instance shall be revoked. The part of KRW 149,964,870 out of the annual payment disposition of KRW 5,419,457,570 that the Defendant rendered to the Plaintiff on July 25, 2017 shall be revoked.

1. Quotation of judgment of the first instance;

The reasoning of this court's judgment is the same as that of the judgment of the court of first instance, and thus, it is cited by Article 8 (2) of the Administrative Litigation Act and the main text of Article 420 of

2. Conclusion

Since the judgment of the first instance is justifiable, the plaintiff's appeal is dismissed as it is groundless.