Seoul High Court 2010Nu41842 ( October 19, 2011)

early 2009west0204 ( October 16, 2009)

It is legitimate that the date of receipt of ownership transfer registration is the time of transfer because the date of payment is unclear.

(C) If the purchase price is calculated based on the conversion price, the acquisition price shall be calculated based on the conversion price, since the actual transaction price at the time of acquisition cannot be confirmed.

Article 162 of the Enforcement Decree of Income Tax Act

2011Du28141 Revocation of Disposition of Imposing capital gains tax

Quantity XX

The director of the tax office.

Seoul High Court Decision 2010Nu41842 Decided October 19, 2011

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but it is clear that the assertion on the grounds of appeal by the appellant falls under Article 4 of the Act on Special Cases Concerning the Procedure for Appeal and therefore, the appeal is dismissed under Article 5 of the same Act. It is so decided as per

Reference materials.

If the grounds for final appeal are not included in the grounds of appeal that make it appropriate for the court of final appeal to become a legal trial, such as matters concerning significant violation of Acts and subordinate statutes, etc., the system of final appeal will not continue to proceed with the deliberation on the merits of the grounds for final appeal, but will not proceed with the deliberation on the merits of the grounds for final