경정청구거부처분취소
1. All appeals filed by the plaintiff and the defendant are dismissed.
2. The costs of appeal shall be borne by each party.
The purport of the claim and appeal is the purport of the appeal.
1. The reasoning of the court's explanation as to this case is as stated in the reasoning of the judgment of the first instance, except where the plaintiff and the defendant added a new or new judgment as to the assertion in paragraph (2) of the same Article, and therefore, they accept it as it is in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.
2. Additional determination
A. The plaintiff's assertion 1) The plaintiff acknowledged the long-term unpaid expenses corresponding to the transfer amount of this case as corporate accounting costs, but it is not recognized as deductible expenses under the Corporate Tax Act until the stock option is exercised. Thus, the plaintiff transferred the above debt to EL card corporation in the course of transferring the business to EL card corporation on October 1, 2007. However, in cases where the plaintiff did not include the above debt transfer in the gross income or make the tax adjustment as to the inclusion in deductible expenses, the transfer margin of the business transfer calculated according to corporate accounting should be excessively calculated compared to legitimate transfer margin under the tax law. Thus, in order to adjust this issue, the transfer amount of this case should be included in deductible expenses for the business year 207 under the Corporate Tax Act, and each of the following facts is not disputed between the parties or acknowledged as deductible expenses under the Corporate Tax Act until the stock option was exercised, and the plaintiff is recognized as having paid the total expenses for stock holding company from 206 to 3006 to 206 new financial holding company from 206.
However, in calculating the tax base for corporate tax, it was not included in the calculation of losses.
② Some of the stock options in the instant case were exercised in 2007, and the Plaintiff was in 2007.