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1. All of the plaintiff's claims are dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
Reasons
1. Details of the disposition;
A. The Plaintiff, as a juristic person engaged in the manufacturing, sales, etc. of non-ferrous metal in Busan Seo-gu, Busan, entered the amount of provisional payments on B, the representative director of which from 2010 to 2012, as shown in the separate payment account book.
B. From March 11, 2014 to April 18, 2014, the Defendant conducted a consolidated corporate tax investigation with respect to the Plaintiff. From 2010 to 2012, the Defendant determined that the Plaintiff entered the amount of KRW 994,50,000 in the aggregate of the provisional payment from B during the business year 2010 to 2011 (i.e., KRW 150,000,000 in the business year 7,000,000 in the business year 2011, and KRW 14,50,000 in the instant provisional payment (hereinafter “instant provisional payment”) as if it were collected in cash without recovering the provisional payment from B, the Defendant issued a false notice of changes in the amount of income by making it a bonus to the Plaintiff’s notice of changes in the amount of income, and calculated the amount omitted in the return of income (the amount of waste sale) as the amount of corporate tax to the Plaintiff on June 22, 2014.
C. On September 3, 2014, the Plaintiff dissatisfied with the decision and filed an objection with the Commissioner of the Busan Regional Tax Office. On October 2, 2014, the Commissioner of the Busan Regional Tax Office stated that “The amount of bonus disposal as to the unpaid portion of the instant provisional payment is revoked as to KRW 994,50,000, and the omission in the return of the sales amount is to rectify the tax base and tax amount of the corporate tax by re-assessment of the waste sales amount,” and that “the omission in the return of the sales amount is to rectify the tax base and tax amount of the tax” was to be disposed of as bonus to the representative on the ground that “the amount of KRW 994,50,000,000 of the provisional payment amount was not deposited in the Plaintiff’s deposit account, etc.” However, the head of the Busan Regional Tax Office stated that “the calculation of the drop amount of the provisional
Accordingly, the defendant shall conduct a partial investigation of the corporate tax of the plaintiff from October 20, 2014 to November 7, 2014, and the above.