1. The appeal by the Plaintiff Samsung Tax Office against the Defendant Samsung Tax Office, and the appeal by the Plaintiff Samsung Tax Office against the Defendant Samsung C.

The reasoning of the judgment of the court of first instance is that of the court of first instance, except for cases where some contents of the judgment of the court of first instance are advanced as follows. Thus, it is accepted by Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

The phrase "whether or not" shall be referred to as "whether or not, etc." in the 8th sentence of the first instance court.

The subject of income belonging to the income of KRW 589 million in the first and second Forms 1 and 2 of the judgment of the court of the first instance shall be “not,” or the subject of income belonging to the sum of KRW 589 million shall not be the Plaintiff, but the Plaintiff shall be the patent patent application and solar construction.”

In addition, the "Reserved" in Part 17 of the 9th judgment of the court of the first instance is called "the subject of income belonging to the said 589 million won or more, which is not the plaintiff, for patent patent and solar construction rather than the plaintiff."

In conclusion, the judgment of the court of first instance is legitimate, and all appeals against the defendant Samsung Tax Office of the plaintiff Samsung Co., Ltd. and appeal against the defendant Samsung Tax Office of the plaintiff Samsung Tax Office of the plaintiff Samsung Tax Office are dismissed.