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1. On December 1, 2016, the Defendant imposed a gift tax of KRW 5,758,930 (including additional taxes) on Plaintiff A for the year 2009.
Reasons
1. Details of the disposition;
A. On November 15, 2007, G Co., Ltd. (hereinafter “H Co., Ltd.”) was established for the purpose of semiconductors, L CD parts processing business, etc. with the trade name “H Co., Ltd.” and Plaintiff F acquired new shares of the instant company (10,000, 50%) on April 17, 2008, and was changed to the trade name as of the same day when Plaintiff F was appointed as the representative director.
B. On June 11, 2009, around 3,500 shares of I, who were the former shareholders of the instant company, (hereinafter referred to as “1 shares”) were transferred to Plaintiff A (Plaintiff F’s private village students), 3,500 shares of J, which were the former shareholders (hereinafter referred to as “2 shares”) to Plaintiff B (the position of inside director of the instant company on June 5, 2009), and 3,000 shares of K, which were the former shareholders, were transferred to Plaintiff F, respectively.
C. Around November 1, 2010, all 1 shares owned by Plaintiff A and 2,500 shares out of Plaintiff F’s shares (hereinafter “third shares”) were transferred to Plaintiff C (the mother of Plaintiff Company L), and 2,500 shares out of Plaintiff F’s shares (hereinafter “fourth shares”) were transferred to Plaintiff B, respectively.
Around March 23, 2012, shares 6,00, which were held by Plaintiff C, were transferred to Plaintiff D (hereinafter “5 shares”) who was employed as an employee of the instant company from January 1, 2010 to Plaintiff D (the time when shares 3 were transferred to Plaintiff D).
E. Around February 12, 2013, shares 2,500 owned by Plaintiff B and shares 2,500 shares 4,000 shares (hereinafter “six shares”) were transferred to M (the two children of Plaintiff F).
F. From October 17, 2014, the 5th 6,00 shares held by Plaintiff D were transferred to N (the time the 5 shares are transferred to N (the time the 7 shares are transferred to N) and to Plaintiff E (the births of Plaintiff F) each (the time the 6 shares are transferred to Plaintiff E; hereinafter “8 shares”) with the 6,000 shares owned by Plaintiff D, and on the same day, 40,00 shares with the face value of KRW 5,000 new shares issued at KRW 5,00 (28,000 shares), P (8,000 shares), Q4.