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1.(a)
On November 1, 2012, the network J and K concluded on 2/10 shares of 644 square meters in North-gu Lbag-gu, Northern-si.
Reasons
1. Facts of recognition;
A. On January 2, 2013 and December 9, 2013, and May 7, 2014, the head of the tax office under the Plaintiff-affiliated Tax Office determined and notified the value-added tax and the comprehensive income tax as stated in the attached Table (However, since the principal tax of global income tax in 2008 was collected before collecting KRW 1,498,080, the principal tax of global income tax in 2008, the amount of KRW 16,126,579). On August 20, 2014, the amount of delinquent tax in arrears is the total of KRW 463,43,560 (hereinafter “instant tax claim”).
B. On November 1, 2012, K entered into a donation contract with the deceased J (hereinafter “the deceased”) and with respect to 2/10 shares, which are the entire shares owned by it, among the real estate listed in paragraph (a) of the Disposition 1 (hereinafter “instant land”). On November 2, 2012, K completed the registration of ownership transfer with respect to the said shares to the deceased on November 2, 2012.
C. The Deceased died on November 15, 2013. The Defendant A inherited the Deceased at the ratio of 21/105, Defendant B, C, D, E, and F, each of 14/105, Defendant G, 6/105, Defendant H, and I, respectively.
[Ground of recognition] Unsatisfy, entry of Gap 1 to 6 evidence, purport of the whole pleadings
2. Determination
A. According to Article 21(1)1 and 7 of the Framework Act on National Taxes regarding preserved claims, each obligation to pay income tax and value-added tax is naturally constituted without any separate act of the tax authority or the taxpayer when the taxable period ends. According to Article 5(1) of the Income Tax Act, the taxable period of income tax is the taxable period.
1. From January 2 to December 31, 199, the taxable period of value-added tax is set forth in Article 5(1)2 of the Value-Added Tax Act.
1.1.1. to 1.0
6. To 30. In the case of paragraph (1) or (2);
7. 1. to 12. 31.
Therefore, among the instant taxation claims, global income tax and value-added tax claims from 2008 to 2011 were already established on November 1, 2012, which was the date of the instant donation contract, and thus, the instant fraudulent act was committed.