whether the subrogation payment is a provisional payment in office;

The amount of subrogated payment seems to have been paid without relation to the plaintiff's business, and even if the amount of subrogated payment was an inevitable means to prevent the plaintiff's future loss or did not have the purpose of tax avoidance, it is not different.

Article 52 of the Corporate Tax Act: Denial of Wrongful Calculation

Article 88 (Calculation Type of Corporate Tax Act)

The plaintiff's appeal is dismissed.

Expenses for appeal shall be borne by the plaintiff.

The judgment of the first instance shall be revoked. The defendant's imposition disposition of KRW 41,970,850 for the plaintiff on September 1, 2004, which exceeds KRW 18,367,290 for the business year 199, and KRW 1,411,320 for the corporate tax of KRW 87,240 for the business year 200, KRW 13,180 for the imposition disposition of KRW 76,51,850 for the business year 200, and KRW 6,13,180 for the imposition disposition of KRW 32,089,510 for the business year 202, and KRW 4,394,70 for the imposition disposition of KRW 32,70 for the business year 202.

1. The reasoning for the court’s explanation concerning this case is as follows, and the reasoning for the judgment of the court of first instance is identical to that for the reasons for the judgment of the court of first instance except for correction as follows. Thus, it is acceptable to accept this as it is in accordance with Article 8(2) of the Administrative Litigation Act and

A. On January 30, 1996, "the plaintiff is a person with a special interest on January 30, 1996" and "21,632,250 won" on January 30, 1996 as "the person with a special interest under Article 52 of the Corporate Tax Act" and "21,632,250 won" on the second 9 side shall be corrected as "21,632,260 won", respectively.

(b) add "a fact that there has been no dispute" in the column for recognition of No. 3 16-17.

(c) To correct "the de facto closure of business" in paragraph 4-9 of the same paragraph as "the de facto closure of business and thus the special relationship is extinguished";

(d) a change of the fifth 5-17 parallels as follows:

"(2) Determination on the interest calculation period"

The non-collectionable claims due to the debtor's insolvency under the Corporate Tax Act fall under the deductible expenses that are deducted from the income of the corporation in calculating the income of the corporation for each business year. In light of the above, regardless of whether the recognized interest, which is included in the gross income under the provisions on the unfair calculation panel, is not recoverable, should be first included in the gross income and deducted from the gross income in the case of bad debts pursuant to the corporate tax laws and regulations. However, if the form of bad debts is not recoverable due to the reasons for the impossibility of recovery, the claims itself exist. Thus, it can be included in the gross income in the calculation of the bad debts for the business year in which the bad debts are confirmed (see Supreme Court Decision 2002Du7227, Dec. 11, 2003). Accordingly, since the recognized interest is included in the gross income regardless of whether it is impossible to recover the original claims, it is legitimate to recognize the plaintiff who has disposed of the claims for indemnity through the resolution of the board of directors until 11.19, 2001.

2. If so, the judgment of the court of first instance is just, and the plaintiff's appeal is dismissed. It is so decided as per Disposition.