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| TITLE | 【Syllabus of Latest Opinion】 Supreme Court Decision 2021Du39997 Decided June 27, 2024 【Lawsuit for Revocation of Disposition Refusing to Rectify Corporate Tax Return】 [full Text] |
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| Summary | |
| 【Main Issues and Holdings】 In a case where a taxpayer who has submitted a tax base return within the statutory due date of return fails to contest the tax authority’s disposition related to the determination or correction that was issued subsequently within the period for filing an objection, whether the said taxpayer may exercise the right to request a correction within a five-year period for filing a request for correction (affirmative) Whether a taxpayer may not only argue that it overreported amounts of tax base for the initial return but also contest the tax authority’s reason for making an adjustment by raising the tax amount together in a lawsuit for revocation of the disposition to refuse a request for a tax reduction (affirmative) In the event of the lapse of the period for filing an objection to the disposition to correct the tax return by raising the tax amount, which was made in accordance with the proviso of Article 45-2 of the former Framework Act on National Taxes, whether a taxpayer may file a request for revocation of the tax disposition only with respect to the initially declared tax base and tax amount (affirmative) | |
