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1. The plaintiffs' claims against the defendants are all dismissed.
2. The costs of lawsuit are assessed against the plaintiffs.
Reasons
Details of the disposition
C A Co., Ltd. (hereinafter “Nonindicted Company”) is a non-listed corporation established with D, the husband of Plaintiff B, as the representative director, for the purpose of manufacturing and wholesaleing semiconductor parts on January 17, 2001.
The Plaintiffs participated in the shares issued on November 5, 2013 by Nonparty Company (hereinafter “instant shares issued”) and acquired 30,000 shares each of them.
(1) The number of shares issued at the end of 2013 and the number of shares issued at the end of 2013 is 2,000.0.00.32,000 B- - 30,0030.30, - 30,000 March 30, 200 - 30, 30,000.30.0 A- - 30,0030.30, 30,0030.30.30, - 30,0030, 30,0030.30,000.30,000; - 30,000,000,000. - 30,000,000, 30,000, 30,000 G 30,50, 25, 205, 205, 25, 201
From June 9, 2015 to July 6, 2015, the Seoul Regional Tax Office conducted a written verification of the change of stocks in the non-party company (hereinafter “instant investigation”). Based on the confirmation of facts and financial transaction statement submitted by the Plaintiffs, the Seoul Regional Tax Office deemed that Non-party company’s representative director and D’s partner E, a partner of the non-party company at the time of issuing new stocks, title trust the instant stocks to the Plaintiffs, and notified the Defendants of taxation data.
Accordingly, on December 3, 2015, the Defendants applied Article 45-2(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 13557, Dec. 15, 2015; hereinafter “Gift”) to determine and notify the Plaintiffs of the gift tax for the year 2013 according to the deemed donation of stocks of this case, each of the gift tax for the year 2013 according to the deemed donation of stocks of this case (including additional tax).
(hereinafter “instant disposition.” The Plaintiffs appealed to the instant disposition and filed an appeal with the Tax Tribunal, and the Tax Tribunal dismissed the Plaintiffs’ claim on September 30, 2016.
【Ground of recognition】 There is no dispute, Gap 1.