Whether the sales amount was disclosed from the company

Where a person fails to make entries in the account book despite the fact of sale, barring any special circumstance, the profit equivalent to the sales amount shall be deemed to have been disclosed out of the company, and special circumstances that the sales amount shall not be disclosed outside the company shall be proved by the claimant.

Article 67 of the Corporate Tax Act

Article 106 of the Enforcement Decree of Corporate Tax Act

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

Although all of the records of this case and the judgment of the court below and the grounds of appeal were examined, the argument on the grounds of appeal by the appellant falls under Article 4 of the Act on Special Cases Concerning the Procedure of Appeal, and therefore, the appeal is dismissed under Article 5 of the same Act. It is so decided as