2. The costs of lawsuit shall be borne by the Plaintiff.

A. On April 8, 2011, the Plaintiff entered into a sales contract for a parcel of land and a building outside C, and three parcels of land at the time of the Government, and received the down payment of KRW 500,000,000 from B (hereinafter “instant payment”).

After that, the above sales contract was terminated because B did not pay the intermediate payment and the balance.

B. On May 2, 2014, the Defendant confirmed the omission of the key source while filing a corporate tax return for the business year 2011, and demanded the vindication therefor.

Accordingly, upon filing a revised return of corporate tax on May 27, 2014, the Plaintiff made a disposition of income in the calculation of earnings and losses (influence of income) on the ground that the representative of the source of key money was set up as the source of key money, and made a disposition of income as a reservation, and additionally included the registration tax, etc., which is an extra expense, in the calculation of losses.

C. However, on August 13, 2014, the Defendant included the issue amount in the gross income, deemed that the issue amount was reverted to the Plaintiff’s representative D, disposed of as a representative bonus, and denied registration tax, etc. as a deductible expense, and issued a notice of the change in the amount of income for the business year 2011 (hereinafter “instant disposition”).

The Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on December 16, 2014, but the Tax Tribunal dismissed the appeal on January 9, 2017.

【Ground of recognition】 The fact that there is no dispute, Gap Nos. 1 and 2, and Eul No. 1 (including branch numbers; hereinafter the same shall apply), the purport of the whole pleadings

2. Whether the disposition is lawful;

A. The Plaintiff’s claim key money source is used in the representative D’s provisional payment system, and thus, the Plaintiff’s disposition of income should be conducted with a reservation that is not an outflow from the company.

Even if not,

Even if 228,347,200 won, such as registration tax, which is off-the-paid expenses (or off-paid fees), and interest expenses, 104,267,391 won, 332,61 won, 614,601 won, are recognized as deductible expenses, and they shall be deemed as offset within the scope on an equal basis with the issues won, and it shall be deemed as offset within the scope on an equal basis with the issues won.