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1. The plaintiff's claim is dismissed.
2. The costs of lawsuit shall be borne by the Plaintiff.
Reasons
Details of the disposition
The plaintiff is a local government-invested public corporation established on February 20, 1993 in accordance with Article 49 of the Local Public Enterprises Act and the Daejeon Metropolitan City Ordinance on the Establishment of Daejeon Urban Corporation.
The director of the Daejeon Regional Tax Office: (a) conducted a tax investigation with the Plaintiff from November 26, 2013 to January 13, 2014; and (b) conducted a tax investigation with respect to the Plaintiff’s new construction and distribution business of 9 block Doan New Apartment City (hereinafter “9 block construction business”); and (c) the Daejeon Daejeon Comprehensive Logistics Complex Development and sale business (hereinafter “Seoul Daejeon Logistics Complex Project”); and (d) with respect to each of the above businesses (hereinafter “each of the above businesses”) (i) presumed the total construction scheduled costs to be excessive during the initial period of the business, and thereafter did not revise and reflect the indirect costs, so that the rate of the work progress is lower than the initial period, thereby delaying the revenue amount. The Plaintiff calculated the amount of revenue underestimated each business year by applying the actual indirect costs invested by the Plaintiff; and (b) calculated the amount of revenue underestimated each business year by calculating it (hereinafter “the issues”); and (c) calculated it as repair expenses for replacement of public rental housing units to be appropriated as non-deductible expenses for each business year.
(hereinafter referred to as “B” issue was notified to the Defendant of taxation data, etc.
Accordingly, on April 3, 2014, the defendant adjusted corporate tax of 2009 to the plaintiff KRW 10,03,00,00,213 (including additional taxes), corporate tax of 2010 to KRW 13,326,605,251 (including additional taxes), corporate tax of 2011 to KRW 7,92,614,861, corporate tax of 2012 to KRW 3,07,309,309,644, corporate tax of 2009 to KRW 3,230,408,360, corporate tax of 2010 to KRW 2,973,914,914,407 (Refund), and notified each of the difference to the plaintiff as 5,540,941,644, corporate tax of 209, corporate tax of 201 to KRW 189,89,898 (Refund).
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