The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined.

1. Review of the reasoning of the lower judgment and the record reveals the following facts.

In around 2003, national credit card companies established the national card system, the credit card company and the national card system specialized in the 16th securitization (hereinafter in sequence referred to as the “16th limited company,” and the “17th limited company,” and collectively referred to as the “instant limited company,” and sold credit card bonds to the instant limited company.

B. At each time of sale, the Plaintiff agreed to grant credit to the securitization bonds issued by the instant limited company based on the underlying asset of the instant credit card bonds.

C. The Plaintiff merged with a national credit card company, from October 2003 to March 2004, received credit card claims from the instant limited liability company and paid money to the instant limited liability company.

(hereinafter) The Plaintiff’s credit card bonds transferred as above are “the instant credit card bonds,” and the money paid by the Plaintiff as above is “the instant money”). D.

Even after that, the Plaintiff purchased several credit card bonds from the instant limited liability company and lent money to the instant limited liability company.

E. In 2003 and 2004, the Plaintiff obtained approval from the Governor of the Financial Supervisory Service for a bad debt on the instant credit card claims, but did not include the instant money in deductible expenses, but was subject to tax adjustment in deductible expenses.

F. The Plaintiff filed a request for correction of corporate tax reduction for each business year from 2007 to 2009 on the grounds that the instant money was included in deductible expenses, but the Defendant rejected the said request for correction.

2. Regarding ground of appeal No. 1

A. citing the reasoning of the judgment of the court of first instance, the lower court, based on the following circumstances, cited the instant funds from the instant limited liability company.