1. The plaintiff's appeal is dismissed.

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

Purport of claim and appeal

The first instance court.

1. The reasons for this part of the disposition are the same as the corresponding part of the judgment of the court of first instance (Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act, since the court’s reasoning for this part is the same as that of the corresponding part of the judgment of the court of first instance (Articles 2 through 15).

2. Whether the instant disposition is lawful

A. The reasoning for this part of the Plaintiff’s assertion is as stated in the corresponding part of the judgment of the court of first instance (Articles 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act, since the reasoning for this part is the same as that of the corresponding part of the judgment of the court of first instance (Articles 8(2) of the Administrative Litigation Act,

B. The instant disposition is lawful for the following reasons.

1) The Plaintiff did not receive the instant shares, regardless of their business affairs, without any consideration or compensation, and received such shares in connection with the Plaintiff’s contribution, i.e., the outcome of business activities. Thus, the instant shares do not constitute the value of assets received without compensation under Article 18 subparag. 8 of the Corporate Tax Act, i.e., the value of assets acquired, i., assets increase profit. ii) even if the instant shares generated from the credit card business succeeded from the Korean credit card, pursuant to Article 18(1)1 of the Enforcement Decree of the Corporate Tax Act, the carried-over losses succeeded from the corporation are excluded from the carried-over losses that

C. The grounds for this part of the relevant statutes are as stated in the corresponding part of the judgment of the court of first instance (Article 8-10 pages). Therefore, this part is cited by Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

Judgment

1. As in a lawsuit seeking revocation of a disposition of rejection against a reduction request as well as a lawsuit seeking revocation of a disposition of rejection, the substantive and procedural grounds for revocation are the grounds for revocation, and the subjects of the trial are set forth in the tax base return.