1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. In order to stabilize the employment and promote the welfare of construction workers, the Plaintiff is a non-profit domestic corporation established on December 9, 1997 pursuant to Article 9 of the Act on the Employment Improvement, etc. of Construction Workers for the purpose of performing mutual aid projects, such as paying mutual-aid money to the beneficiaries of construction workers.

B. On May 25, 2012, the Plaintiff filed a claim for correction of KRW 273,712,670 as the reserve fund for non-profit domestic corporations under Article 29 of the former Corporate Tax Act (amended by Act No. 10423, Dec. 30, 2010; hereinafter the same) by omitting interest income of KRW 1,443,965,937 at the time of filing the tax base return in the business year of 2010, which was not included in deductible expenses. As such, the Plaintiff filed a claim for correction of KRW 273,712,670

C. Accordingly, pursuant to Article 62(1) of the former Corporate Tax Act and Article 99(2) of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 22577, Dec. 30, 2010), the Defendant rejected an application for rectification filed on May 25, 2012 on the ground that the interest income for which a corporation failed to file a tax base return cannot be included in the tax base based on a revised return, a return after the deadline, a correction, etc., and the Plaintiff did not file a report on the amount of the interest income at the time of filing a corporate tax for 2010 business year

Furthermore, when the plaintiff returns corporate tax for the business year 209 and 2010, the defendant applied the error of the year to which the interest income belongs to the inclusion of the tax base and the reserve fund for proper purpose business for the pertinent year, and determined that the tax was excessively refunded, and accordingly, the defendant issued the plaintiff a disposition of imposing corporate tax of 378,982,080 won (286,825,160 won over-paid tax amount) for the business year 2009, and 534,744,840 won of corporate tax for the business year 2010 (286,156,923 won over-paid tax amount), and 534,74,840 won of corporate tax for the business year 2010 (441,063,050 won over-paid tax amount) (93,681,791 won).