1. The plaintiff's appeal is dismissed.

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

The purport of the claim and appeal is the purport of the appeal.

The reasoning of the judgment of this court citing the judgment of the court of first instance is as stated in the reasoning of the judgment of the court of first instance, except for the dismissal of 10 to 18 pages 4 of the judgment of the court of first instance as follows. Thus, this is accepted in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 4

[Attachment] Article 14(1) of the Corporate Tax Act provides that “The income of a domestic corporation for each business year shall be the amount calculated by subtracting the total amount of losses incurred during the business year from the total amount of earnings accrued during the business year.” Article 19(1) provides that “deductible expenses shall be the amount of losses or expenses incurred by transactions that reduce net assets of the relevant corporation, excluding refund of capital or financing, disposition of surplus funds, and those prescribed in this Act.” Article 19 subparag. 7 of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 28640, Feb. 13, 2018; hereinafter “former Enforcement Decree of the Corporate Tax Act”) provides that “loan interest” as one of losses.

In addition, Article 40(1) of the Corporate Tax Act provides that "the fiscal year of accrual of earnings and losses of a domestic corporation for each fiscal year shall be the fiscal year which includes the date on which the concerned earnings and losses are settled."

In full view of the above provisions, the interest rate on the loan should be included in the calculation of losses for the business year in which the disbursement was finalized.

In conclusion, the judgment of the first instance is justifiable, and the plaintiff's appeal is dismissed as it is without merit.