The bonus disposition at the time of closure of the business shall be whether the bonus disposition at the amount of the provisional payment is properly made (defensive dismissal)

No special circumstance exists to deem that the special relationship was extinguished on the cessation date, and since the provisional payment and interest of the instant case were collected before the special relationship was terminated, it cannot be deemed that the instant provisional payment and interest were leaked out of the private company.

Article 67 of the Corporate Tax Act

The appeal is dismissed.

The costs of appeal are assessed against the defendant.

All of the records of this case and the judgment of the court below and the grounds of appeal were examined, but it is clear that the appellant's grounds of appeal fall under Article 4 of the Act on Special Cases Concerning the Procedure of Appeal and therefore, the appeal is dismissed pursuant to Article 5 of the above Act. It is so decided as per Disposition by