1. Of the portion against the defendant in the judgment of the court of first instance, the portion of the additional tax of KRW 100,000,000 among the corporate tax reverted for the business year 207, and that of the additional tax.

1. Of the reasoning of the judgment of the court of first instance, the part pertaining to “determination on the grounds of disposition, the Plaintiff’s assertion, the expenses for promotion of overseas markets, and non-real-name compact,” and the part pertaining to the pertinent part of the judgment of the court of first instance, except for the addition as follows, is the same as the corresponding part of the judgment of the court of first instance (Articles 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act. Therefore, this part is cited as it is in accordance with the foregoing provisions.

In light of the provisions of Section 18 of the first instance judgment, the actual substance of the transaction shall include the following in advance of the “in light of” of the 10th written judgment:

The plaintiff argues that the overseas sales promotion expenses incurred by the plaintiff were recognized as losses by the tax authority for the existing customer, and therefore the overseas sales promotion expenses incurred by the plaintiff are also deductible expenses. However, according to the result of the fact-finding on the Pakistan of this court, it is recognized that Pakistan was recognized as deductible expenses by proving that it was entered into and managed by each customer in the company's ERP system, while there is no evidence suggesting that the plaintiff was engaged in such strict management as to the overseas sales promotion expenses; 6) there is no evidence suggesting that the overseas sales promotion expenses have the effect of promoting normal game participation, such as providing the operator's chips that can be used only within the casino or directly convenience in casino games.

2. Determination on the issue additional tax

A. The facts of recognition 1) The Plaintiff’s contract and performance (a) “Surgyy’s leisure set-up Anniver Symym Annives Over” (hereinafter “Surgy”) is a casino customer recruitment business entity specialized in the Hong Kong, which is a Memeri group’s relationship with the Philippines located in Hong Kong.

B. On June 30, 2007, the Plaintiff’s casino is not a customer’s casino instead of soliciting and arranging customers.