1. Revocation of a judgment of the first instance;

2. The plaintiff's claim is dismissed.

3. All costs of the lawsuit shall be borne by the Plaintiff.

1. The reasons for the entry of this case by the court of first instance concerning this case are as stated in the reasons for the judgment of the court of first instance in addition to the use of a part of the judgment of the court of first instance as set forth in the following paragraph (2). Thus, this is cited by Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420

(hereinafter the meaning of the abbreviationd language used in (hereinafter the same shall apply to the judgment of the court of first instance). 2. the second parallel "the same day" in the second parallel of the second parallel of the second parallel of the second parallel of the same line of the same line of the same line shall be applied. The fourth parallel of the Corporate Tax Act (amended by Act No. 15222, Dec. 19, 2017; hereinafter the same shall apply) shall be deemed to be "the former Corporate Tax Act (amended by Act No. 15222, Dec. 19, 2017; hereinafter the same shall apply)", and the first eight parallel "

"Flags".

The 4th parallels 20 to 5th parallels shall be followed as follows:

According to Article 3(3)5 of the former Corporate Tax Act and Article 2(2) of the former Enforcement Decree of the Corporate Tax Act, income generated from the disposal of fixed assets of non-profit domestic corporations is, in principle, included in the scope of taxable income subject to corporate tax: Provided, That the income generated from the disposal of fixed assets directly used for the proper purpose business for at least three consecutive years as of the date of disposal of the fixed assets concerned shall be excluded from the scope of taxable income. In light of the form and text of the provision, the taxpayer must prove that the fixed assets concerned fall under the “fixed assets used directly for the proper purpose business for at least three consecutive years as of the date of disposal” and are excluded from the scope of taxable

Non-taxation

One of the cases can be determined differently within the scope of legislative discretion in consideration of the legislative intent of each individual statute, so it is three years from the time of acquisition to the time of transfer as alleged by the plaintiff, notwithstanding the phrase "for more than three consecutive years as of the date of disposition".