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(영문) 서울행정법원 2014.09.16 2014구합53452
소득금액변동통지 등 취소
Text

1. On September 3, 2013, the Defendant issued a notice of change in the amount of income as set forth in attached Table 1 Nos. 1, 2, and 3 against the Plaintiff.

Reasons

1. Details of the disposition;

A. The plaintiff is a juristic person established on September 15, 199 and engaged in the business of selling, exporting, and importing, etc. documents management equipment, and B is serving as the representative director of the plaintiff since its establishment.

B. From January 30, 2013 to May 12, 2013, the Defendant: (a) conducted an integrated investigation into corporate tax against the Plaintiff; (b) confirmed the fact that the Plaintiff, from 2002 to 2004, 2006, and 2010, imported products from foreign customers to supply them to domestic customers; (c) omitted the return of corporate tax and value-added tax on KRW 1,066,513,007, which the Plaintiff received from foreign customers in the course of importing products from foreign customers; and (d) during the taxable period of value-added tax from 203 to 1,741,815,360, the value-added tax and corporate tax was reported by deducting the relevant input tax amount from the output tax amount; and (e) deducting the value-added tax amount from the output tax amount and the said value-added tax was included in deductible expenses.

C. On September 3, 2013, the Defendant included the omitted return amount of the Plaintiff’s brokerage commission in the calculation of earnings, deducted the input tax amount from the receipt of a false tax invoice, added the value-added tax and corporate tax for each business year from 2003 to 2006, and notified a correction of the value-added tax and corporate tax by each business year. On the other hand, only the amount confirmed as the settlement amount of revenue equipment out of the omitted return amount of the brokerage commission commission in the calculation of earnings, disposed of as other outflow of income, and disposed of the remainder of the return amount of the brokerage commission and the supply amount received by false tax invoice (hereinafter “the instant income amount”) as bonus to the representative director B, who belongs to the Plaintiff, as the bonus (hereinafter “the instant income disposition”). On September 3, 2013, the Defendant notified the Plaintiff of

(hereinafter “Notice of Changes in Each Income Amount of this case”) D.

The Plaintiff’s each of the instant cases on September 16, 2013.

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