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

A. On November 19, 2010, Plaintiff 1, a company engaged in the manufacturing and sirening business of cold and hot water purifiers, concluded a contract with the Plaintiff to transfer the water purifiers sponsing credit and rights incidental thereto (hereinafter “instant transfer contract”) owned by the Plaintiff (hereinafter “BB”). On November 30, 2010, Plaintiff 1, under the terms and conditions of the said contract, concluded a contract with the Plaintiff on the transfer of the water purifiers sponsing credit and the rights incidental thereto (hereinafter “the instant claim”). On November 30, 2010, Plaintiff 1 expressed both the BBB BB claim totaling KRW 00,000 in the instant claim (hereinafter “the instant claim”).

B. After that, on November 25, 2011, the Plaintiff appropriated a total of KRW 0000 as the cost incurred in the year 2010 and completed a corporate tax return against the Defendant, which is expected to be paid after November 25, 2011.

C. However, the instant costs, however, constituted deductible expenses to be included in the business year including the date on which the obligation to pay comes after the time of replacement of water purifiers was determined, and on March 21, 2012, the Defendant issued a disposition of imposition of KRW 000 of the corporate tax for the year 2010 calculated by adding the instant costs to deductible expenses to the Plaintiff (hereinafter “instant disposition”).

D. The Plaintiff appealed and filed an appeal with the Tax Tribunal on June 12, 2012, but on September 2012.

17. A decision of dismissal was rendered.

[Ground of Recognition] The non-satched facts, Gap evidence 1, 2, and Eul evidence 1, 2, and 3 (including any number), and the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The plaintiff's assertion

The instant expenses are expenses incurred in the use of water purifiers, which have already been determined at the time of the transfer of the instant claims, and should be included in deductible expenses for the 2010 business year in which the instant claims were transferred, and such deductible expenses method conforms to the corporate accounting standards stipulated in Article 43 of the Corporate Tax Act. Therefore, the instant disposition taken on a different premise is unlawful.

B. Relevant statutes

The entries in the attached Table-related statutes are as follows.

C. Determination

1) Relevant legal principles

Article 14 of the Corporate Tax Act provides that income for each business year of a corporation shall be the amount calculated by deducting the total amount of deductible expenses belonging to the business year from the total amount of gross income in the business year, and Articles 15 and 19 of the same Act provide that gross income shall be the amount of earnings accruing from transactions which increase the net assets of the corporation concerned, and deductible expenses shall be the amount of losses incurred from transactions which reduce the net assets of the corporation concerned, and the amount of losses shall be generally accepted as ordinary or directly related to profits or losses generated or spent in connection with the business of the corporation, and Article 40 of the same Act provides that the business year in which gross income and deductible expenses accrue shall be the business year in which the date when the profit and deductible expenses are determined belongs. According to the above provisions, the Corporate Tax Act adopts the principle of response to profits and deductible expenses with respect to the business year of accrual of gross income and deductible expenses, and (i) The time when the liabilities are determined is included in the calculation of earnings or indirect expenses of the corporation for the business year in which it is not directly related to profits or losses, as the specific business year.

2) Determination

According to the health stand, Eul evidence Nos. 2 and 3, and Eul evidence Nos. 4-1 and 2 as to this case, among the water purifier string forms in which the plaintiff concludes with many and unspecified persons, Article 11 provides that the plaintiff is treated without compensation, and the repair of defects and replacement of parts caused by manufacturing defects within the contract period from the date of installation of water purifiers, and the repair of defects and replacement of parts caused by users' care and use are processed with compensation, and Article 10 of the transfer contract of this case provides that the transferor is the transferor's duty to A/S, and the plaintiff is the transferor's duty to recover the whole assets by BB.

The term "A/S obligations" and "A/S obligations under the rental agreement" mean all services to be provided to the other party to the siren agreement for the purpose of maintaining the water purifiers inspection and lot replacement agreement under the rental agreement (paragraph 2), and "the plaintiff shall report to BB the customer information set up at the fifth day of each month and the information on sub-A/S organizational network, etc. (paragraph 3), and "OOO shall not be deemed to have any further difficulty in carrying out A/S work, and if it is determined that it is difficult for the plaintiff to carry out the above tax accounting standards, the plaintiff shall select A/S companies and have them carry out the A/S work (paragraph 4), and if it is so determined that it is difficult for the newly selected A/S companies to carry out the tax accounting standards at the time of the transfer agreement, the plaintiff shall not be required to cooperate with the other party, and if so, the plaintiff shall not be required to carry out the assigned expenses under the above separate accounting standards for the business year when it comes to fall under the first / 20 years after the transfer agreement.

3. Conclusion

Then, the plaintiff's claim is dismissed as it is without merit. It is so decided as per Disposition.