법인세부과처분취소
1. The plaintiff's appeal is dismissed.
2. The costs of appeal shall be borne by the Plaintiff.
Purport of claim and appeal
The first instance court.
The reasoning for admitting the judgment of the first instance court is as follows. As such, Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act are cited for the reasons for admitting this case. The part of the judgment of the first instance (2.(b) judgment “2.(3)” in the reasoning of the judgment of the first instance (2.b.(3) is as follows: 3). According to the above facts, the donations in this case were legitimate donations to the State or local governments under Article 24(2)1 of the Corporate Tax Act. However, considering the above facts, it is reasonable for the Plaintiff to include the Plaintiff’s contributions in deductible expenses at the time of 20% as well as the Plaintiff’s wrongful calculation of the total amount of the Plaintiff’s contributions in accordance with the principle that the Plaintiff did not have any special relationship with the State or local government under Article 24(2)1 of the Corporate Tax Act, and thus, it is reasonable for the Corporation to recognize the Plaintiff’s appearance of the donations in this case to be included in deductible expenses.
At the time when the board of directors of the Plaintiff decided to contribute funds to the time of Taesan, the Plaintiff was merely the convertible bonds of the Taecheon Tourism Development Corporation, not the shareholders, and thus is not specially related to the said Corporation.