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 concerning this case is 3.B.

Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act shall be cited as it is for the first instance court’s reasons, except for adding the following provisions to the end of the business year subject to inclusion of earnings and losses in deductible expenses (the third claim). In other words, it is necessary to add the transfer funds in this case to deductible expenses at the end of the business year subject to inclusion of earnings and losses in deductible expenses (the third claim) and the end of the business year subject to inclusion in deductible expenses (the third claim), i.e., transferring the transfer funds in this case to non-profit business accounts in the business year 209 to deductible expenses, notwithstanding Article 76(4) of the former Enforcement Rule of the Corporate Tax Act, if a non-profit corporation was appropriated as deductible expenses for the purpose of the business year subject to inclusion in deductible expenses, the non-profit corporation cannot be directly included in deductible expenses for the purpose of Article 209 of the former Corporate Tax Act (the second claim).