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Reasons
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(영문) 서울행정법원 2015.12.04 2015구합2673
종합소득세부과처분취소
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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. On June 28, 201, the Plaintiff, a joint representative director of the Company B (hereinafter “Nonindicted Company”) entered into a contract with the said Company to transfer KRW 13,000 (hereinafter “instant shares”) of the non-listed stocks issued to the said Company C (hereinafter “C”) to KRW 50,000 (50,000 per share) (hereinafter “instant agreement”), including the following special agreement (hereinafter “instant acquisition of shares”), and received payment of KRW 650,00,000 from the Nonparty Company on June 29, 201.

Article 2 (Special Agreements)

1. Until September 15, 2011, the Plaintiff guarantees to the non-party company that “D” products developed in C and owned a patent will be concluded with SAm UNG, NOKA, MOTROLA, and other MM low-scale manufacturer(s) and supply contract on a quantity of mass products.

2. If the conclusion of the supply contract of the quantity in mass specified in paragraph 1 above is delayed or postponed, the plaintiff and the non-party company agree to adjust the price of stock as follows:

1) The price of acquisition of shares: The total amount of acquisition price at a discount of gold l0,000 won (27,000): The amount of gold l351,000,000 won (351,000,000) shall be adjusted.

3) On September 20, 201, the Plaintiff returned the purchase price of the instant shares to the Plaintiff with the acquisition price of KRW 351,000,000 (27,000 per share) of KRW 299,000,000 (299,000,000) that was paid by the non-party company to the Plaintiff on September 29, 201, the difference between the acquisition price and the acquisition price of the instant shares is to be refunded to the corporate passbook designated by the non-party company within one week (7 days).

C. On September 14, 2012, Nonparty Company reported corporate tax for the business year 2011 by appropriating the instant shares as assets. However, on November 5, 2012, the Gangnam-gu director of the tax office (the director of the tax office).

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