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수용된 토지의 양도시기 관련 심판례




【 결정요지】
   
- 양도시기에 대하여 규정하고 있는 소득세법 제98조 및 동법시행령 제162조 제1항을 보면 원칙적으로 대금청산일을 양도시기로 하면서 대금을 청산하기 전에 소유권이전등기를 한 경우에는 등기접수일을 양도시기로 하고 있음.

 - 청구인은 당초 보상금재결에 불복하여 중앙토지수용위원회에 이의신청을 제기하고 그 이의재결(2006.10.26.)에서 보상금이 증액되어 추가보상금이 공탁된 경우에는 추가보상금이 공탁된 날(2006.12.4.)이 대금청산일이라고 할 것임.

 - 따라서, 쟁점토지 대금청산일(2006.12.4.)과 소유권이전등기 접수일(2006.8.18.)중 빠른 날인 등기접수일이 쟁점토지 양도시기가 될 것이므로 당초 보상금 공탁일(2006.3.20.)이 양도시기라는 청구주장은 타당하지 않은 것으로 판단됨.


DATE : 2007-12-28 10:44
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