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.

1. The reasoning of the court's explanation of this case is as stated in the reasoning of the judgment of the court of first instance, except for the addition of the following two paragraphs to the judgment of the plaintiff as the grounds for appeal, and thus, it is acceptable to accept this as it is in accordance with Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

2. Additional determination

A. The Plaintiff’s assertion that the key amount of the instant case was accounted for as the representative director’s provisional income, but this was used as the total amount of the Plaintiff’s operating fund as a processed debt only on the pretext of the failure to set up a counter-inform. In fact, as a resolution of the board of directors on December 10, 2013, even though the said provisional income was not leaked as a profit from debt exemption, it was unlawful for the Defendant to dispose of the key amount as the bonus of the representative director D against the principle of substantial taxation.

B. According to the following facts found by the evidence of the judgment of the court of first instance, it is difficult to recognize special circumstances, such as: (a) it is difficult to recognize that the obligation of provisional receipts equivalent to the amount of the issue in this case is a nominal processing obligation, for which no counter-inform is scheduled; and (b)

1) The Plaintiff had conducted a short-term and long-term loan transaction with shareholders since before the business year 2010. In particular, during the business year 2010, the Plaintiff continued to borrow and counter-loan loans from several times or several times a month with the representative director D (the evidence No. 4, No. 7). The total amount of short-term loan of shareholders officers in the business year 2010 increased in the business year 2010 (the long-term loan of shareholders officers in the business year 2010 increased in KRW 1,037,463,00, and the total amount of short-term loan of shareholders officers in the business year 765,219,000, reduced in KRW 334,064,00 for short-term loan of shareholders officers in the business year 2012, the short-term loan of shareholders officers in the business year 2013 decreased in KRW 887,217,000,104,785,000.

It cannot be viewed as a provisional payment that is not scheduled to be a semi-annual payment; and