1. The defendant's appeal is dismissed.

2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

1. The reasoning of the judgment of the court of first instance cited by the court of first instance is as follows, and thus, it is consistent with the reasoning of the judgment of the court of first instance, and thus, by Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act

According to the principle of separate accounting of profit-making business and non-profit-making business, the part that "the transactions between profit-making business and non-profit-making business shall be perceived as the transactions between third parties, although they are internal transactions between profit-making business and non-profit-making business" shall be deleted.

Part 6 "(including bonuses)" in Part 19 shall be raised into "(including surplus earnings)".

The second part of "for-profit business" shall be referred to as "for-profit business sector".

Part 9 of Part 13 "A case where assets belonging to other business are disbursed for profit-making business" shall be deemed to be "a case where assets belonging to a profit-making business are disbursed for other business."

1. The part of paragraphs 7-19 (7) and 7 shall be advanced as follows.

7. The defendant asserts that "the plaintiff offsets the market price of 15,412,567,930 won by the reserve fund for proper purpose business under general rule 113-1563 of the Corporate Tax Act while transferring the real estate of this case into the proper purpose business (=total book value and evaluation profits)." Thus, the remaining appraised profits obtained by subtracting the book value of 2,432,489,821 won from the above amount under the principle of double-entry bookkeeping (the principle of balance of loans) shall be included in gross income." However, if assets used for profit-making business of non-profit corporations are transferred to the proper purpose business, the appraised profits shall not be considered as transfer of assets, and the appraised profits shall not be considered as the transfer of assets, and if they are disposed of to the third party after the principle of balance of loans and loans is satisfied, they shall be assessed profits and losses.