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(영문) 서울행정법원 2015.07.02 2014구합76165
소득금액변동통지처분취소
Text

1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

Reasons

1. Details of the disposition;

A. At the time of the business year from 2008 to 2011, the Plaintiff excluded the amount of KRW 5,357,704,00 (hereinafter the same shall apply in this paragraph) that was the representative director of the Plaintiff Company B, C, D Management Team C, F Management Team G, and the principal officer of the same Section Management Team of the same Section (hereinafter “B, etc.”) embezzled through a provisional park’s appropriation from deductible expenses, and paid the corporate tax base and tax amount of KRW 2,477,823,00 (hereinafter the same shall apply in this paragraph) on January 21, 2013 by filing a revised return, while paying the tax base and tax amount of the corporate tax on KRW 2,879,81,00 (2,879,881,00 won for 208, 965,407,000 for 209,2527,300,000 won for 301,501,7010

B. From February 25, 2013 to May 15, 2013, the Defendant conducted an integrated investigation of corporate tax for the business year 2007-201 with respect to the Plaintiff from February 25, 2013 to May 15, 2011, confirmed that, in addition to the Plaintiff’s revised return amount, the inclusion of the processed expenses of KRW 3,143,802,00 (hereinafter the same shall apply in this paragraph) in addition to the amount of the Plaintiff’s revised return, the Defendant corrected corporate tax for the pertinent business year by non-Inclusion of the amount, and the aggregate amount of KRW 8,501,506,506,500 (=3,5357,704,000,000) was leaked (i.e., KRW 5,353,704,02,000, the detailed contents were as indicated below) and disposed as bonus to the representative director of the pertinent business year as well as the notice of the change in the income amount (hereinafter “instant”).

1. The statement on the calculation of the plaintiff's processing expenses (unit: 20,008 965,407 1,58,802 185,000 2,477,823-5,217,032,743 220,000 - 80,000 - 150,7432,2010,743201, 261, 753 - 20,261, 203 - 20,2653 - 205,208 - 19,978 265,000- - 435,000,319, 319, 878, 2008, 205, 207, 208, 207, 208, 2005, 748, 2007

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