Whether via the pre-trial procedure and the provisional park are appropriate;

Income tax and corporate tax should be treated separately by tax authorities and taxpayers, and they should go through the pre-trial procedure. In addition, it is legitimate for the Defendant to dispose of the provisional park as non-deductible expenses.

Article 55 (Objection) of the Framework Act on National Taxes, Article 66 (Determination and Correction) of the Corporate Tax Act

1. All appeals filed by the plaintiffs are dismissed.

2. The costs of appeal are assessed against the Plaintiffs.

The judgment of the first instance is revoked. The imposition of KRW 56,724,440 on January 2, 2004 against the Plaintiff ○○ Construction Co., Ltd. of KRW 56,724,440 on July 1, 2004; the imposition of KRW 92,576,170 on global income tax for the year 199 against the Plaintiff ○○○○ on July 1, 2004; and the imposition of KRW 9,257,610 on global income tax for the year 199 against the Plaintiff ○○○○ on July 1, 2004.

The reasoning for the court's explanation on this case is that "○○ Construction Co., Ltd." in the second 10th 2th 10th 10th 2th 2th 10th 2th 2th 3th 3th 13 and 14th 3th 14th 2004 were "the third 30.7. 30th 2004" and "the third 16th 2004 had filed an objection with the director of the tax office on March 16, 2004, and the decision of dismissal was made on April 22, 2004", and "the 5th 5th 6th 5th 6th 5th 6th 5th 6th 5th 6th 6th 5th 6th 6th 6th 6th 6th 6th 6th 6th 6th 200

Therefore, the judgment of the first instance is just, and the plaintiffs' appeal is dismissed as it is without merit, and it is so decided as per Disposition.