The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. As to the grounds of appeal Nos. 1 and 2 of the spectrum (hereinafter “the grounds of appeal No. 1”) and the grounds of appeal Nos. 2, 3, and 4 of the law firm Bupyeong (hereinafter “the grounds of appeal No. 2”)

A. The court shall decide whether the assertion of facts is true in accordance with logical and empirical rules, taking into account the purport of the entire pleadings and the results of the examination of evidence, based on the principle of social justice and equity. The court of final appeal shall bind the court of final appeal as to the facts duly established, as the judgment below does not exceed the bounds of the principle

(Article 8(2) of the Administrative Litigation Act, Articles 202 and 432 of the Civil Procedure Act, and Article 29(1) of the former Corporate Tax Act (amended by Act No. 9898, Dec. 31, 2009; hereinafter the same) provide that where a non-profit domestic corporation appropriates reserve funds for proper purpose business to its deductible expenses for each fiscal year in order to disburse them to its proper purpose business, etc., it shall be included in deductible expenses within a certain limit.

B. For reasons indicated in its reasoning, the lower court: (a) on May 7, 2009, the Plaintiff, a private school corporation, deposited the sales price received by the Plaintiff from the former assets, which are fundamental property for profit-making purposes, in a fixed-term deposit account, which is an asset for non-profit business; and (b) transferred the sales price to a non-profit business account, the difference between the acquisition price and the acquisition price of the previous assets, which is the difference between the purchase price and the acquisition price of the previous assets; (c) however, it is deemed that the Plaintiff planned to purchase the instant substitute assets, which is a scheme for using compensation for losses, by recognizing the possibility of sale of the previous assets before receiving a request for consultation on compensation for losses from the Korea Water Resources Corporation.