1. The defendant's appeal is dismissed.

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

3.Paragraph 1 of the text of the judgment of the court of first instance.

1. The reasoning of the judgment of the court of first instance 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, since the reasoning of the judgment of the court of first instance is the same as that of the judgment of the court of first instance, except for the following matters:

The "direct foreign tax amount paid" in each of the 3th parallel 7th parallel 6th parallel 6th parallel 6th parallel 6th parallel 1st parallel 15th parallel shall be deemed "direct foreign tax amount paid".

Each "indirect paid foreign tax amount" of 5.7 parallel 7.6 parallel 3 parallel 3 parallel 3 parallel 6.

5. The 7th page "Inclusion in gross income" shall be deemed to be "not inclusion in gross income".

Each "Corporate Tax Law" of 7, 15, 8, 20 shall be raised to "former Corporate Tax Act".

8 Myeon 14 "The above-mentioned amount" shall be deemed as "the above-mentioned amount shall not be included in deductible expenses".

9. In two pages, the phrase “if it is impossible to look at and if a taxation is to be made because it is not possible to look at, etc., it would result in imposing taxes on it that is not an actual income.”

9 pages 6 and 7 are referred to as “not to be included in gross income” as “not to be included in deductible expenses.”

9. The "foreign tax amount" of the 16th 16th e.g. shall be raised as "foreign corporation tax amount".

From 10 pages 2 to 11, parallel 11, parallel 2 to the following:

“D) The Defendant asserts that the meaning of “the tax base of corporate local income tax” under Article 103-19 of the former Local Tax Act should be construed as having the same meaning as the tax base of corporate tax and corporate local income tax under Article 13 of the former Corporate Tax Act.

However, in light of the above relevant laws and the purport of the entire pleadings, it is reasonable to interpret that the above language and text of Article 103-19 of the former Local Tax Act provides that the method of calculating the tax base shall be followed by the Corporate Tax Act, and it is difficult to view otherwise solely on the basis of the evidence Nos. 1, 2, and 3.

Therefore, the defendant's above assertion.