All appeals are dismissed.

The costs of appeal are assessed against the plaintiffs.

The grounds of appeal are examined.

1. Wage and salary income under Article 20(1) of the former Income Tax Act (amended by Act No. 14389, Dec. 20, 2016) includes not only all economic benefits, regardless of its payment form or name, which are related to the provision of labor, but also benefits closely related to the provision of labor on the premise of labor, in addition to direct labor (see Supreme Court Decision 2007Du1941, Oct. 25, 2007). Meanwhile, in order to ensure that income subject to taxation has been realized, even if it is not necessary until the income is realized, it shall be considerably mature and confirmed in the possibility of realizing the right to generate income, and it shall not be said that there is no income at the stage that the right to generate income comes into existence without reaching such degree.

Whether the right to receive income is mature and finalized shall be determined by comprehensively taking into account the nature and contents of each specific right and various legal and de facto matters.

In particular, in a case where there is a dispute over the existence and scope of claims between a payer of income and a beneficiary, the right to generate income cannot be deemed to have been established unless it is clearly unreasonable in light of the circumstance of the lawsuit and the nature of the case, etc.

(See Supreme Court Decision 96Nu2200 delivered on April 8, 1997). 2. Review of the reasoning of the lower judgment and the record reveals the following facts.

(1) On December 1, 2005, the Plaintiffs joined C Co., Ltd. (hereinafter “C”) and were appointed as a director on April 13, 2007.

At the time of service C, the Plaintiffs were in charge of the authorization and permission related to the approval for the tourism business of the D District, and after the approval for the business, the Plaintiffs were in charge of the overall affairs or the golf course design.