Seoul High Court-2018-Nu-78567 (2019.06.07)

Cho Jae-2017-west-3709 ( October 18, 2017)

(Restatement of the Reasons for Appeal) It is reasonable to see that it is a non-business interest because it is difficult to see that the money was continuously and repeatedly lent for profit-making purposes.

(C) It is reasonable to view that the term of loan and the number of times is very limited, and that the term of loan and the number of times seems to have not been advertised through the former land, etc., and that the money has been lent to a specific person who has been limited for a certain period, and that it is difficult to see that the money has been lent to an unspecified

Article 16 of the Income Tax Act

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

In accordance with Article 8(2) of the Administrative Litigation Act, Article 429 of the Civil Procedure Act, and Article 5 of the Act on Special Cases Concerning the Procedure for Final Appeal, since a petition of appeal filed by an appellant does not contain any statement in the grounds of appeal, and it is so decided as per Disposition by the assent of all