The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined.

1. Article 21 (1) of the Income Tax Act provides that "other income shall be income, other than interest, dividend, business income, earned income, annuity, retirement income, and capital gains, which is stipulated in any of the following subparagraphs," and subparagraph 19 of the same Article provides that "compensation" shall be provided in subparagraph 17, and subparagraph 19 of the same Article provides that "the price received for personal services (excluding the services subject to subparagraphs 15 through 17) falling under

(1) The term “services 17” and “No. 19, etc.” are “services 17” and “other services provided without an employment relationship for remuneration or other similar consideration by an attorney-at-law, certified public accountant, etc. or any other person with professional knowledge or special skill, by taking advantage of his/her knowledge or skills,” and “services 17” and “other services provided without an employment relationship for remuneration or other similar consideration for remuneration or other similar consideration by a person having a special skill or special skill, such as attorney-at-law, certified public accountant, etc.,” and “other services provided without an employment relationship, for consideration or other similar consideration.”

On the other hand, the amount of other income shall be calculated by deducting necessary expenses from the total amount of income in the relevant taxable period (Article 21(2) of the Income Tax Act), and the necessary expenses shall be calculated as “the total amount of expenses corresponding to the total amount of income in the relevant taxable period, which is generally accepted,” except as otherwise provided (Article 37(2) of the Income Tax Act). Since there is no different provision as to the honorarium under subparagraph 17 of the same Article

On the other hand, with respect to other income under subparagraph 19, the “amount equivalent to 80/100 of the received amount” shall be deemed necessary expenses, and if the actual amount exceeds the amount equivalent to 80/100, the exceeding amount shall also be deemed as necessary expenses.