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.

The reasons for the judgment of this court are as follows: “No difference exists” in the fourth 10th 10th 10th son of the judgment of the court of first instance; “No difference exists” in the first 11th son; and “the plaintiff also did not dispute the fact that the ATRESL is an intentional company established for the purpose of tax avoidance at the stage of the decision of pre-assessment review; and therefore, it is identical with the reasons for the judgment of the court of first instance. Therefore, it is cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

The plaintiff asserts that the payment of this case does not constitute interest income in this court.

However, even if the Plaintiff, a surety, paid the instant payment, the nature of the instant payment income shall be deemed to be the basis for the payment guarantee obligee vested in the instant payment. The instant payment falls under the interest income under Article 16 (1) 7 of the former Income Tax Act on the ground that the instant payment falls under “interest and discount amount of bonds or securities issued by a foreign corporation” under Article 16 (1) 7 of the former Income Tax Act or “income similar to those under subparagraphs 1 through 12 of Article 13, which has the nature of consideration following the use of money.”

Therefore, this part of the plaintiff's assertion cannot be accepted.

The judgment of the first instance is justifiable.

The plaintiff's appeal is dismissed.