1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The purport of the claim and appeal is the purport of the appeal.

The reasoning of this court's judgment citing the judgment of the court of first instance is 2-2 '2 '2 '3 '2 - 12 - 12 - 6 - -

Inasmuch as Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act are the same as the reasoning of the judgment of the court of first instance except for an appeal as follows:

[Attachment]

B. 1) The Plaintiff’s assertion that the construction cost for replacing paintings and projecting lights should be included in the necessary expenses, and the Defendant’s assertion is the amount of KRW 376,298,635, which the Plaintiff and two other parties incurred in relation to the building of the instant golf range (the amount indicated in the instant sales contract at the value of equipment, etc.)

Of the instant real estate, the instant real estate was seriously damaged due to typhoons in August 2012, and thus did not have to perform large repair and remodelling works in order to recover its function as a driving range. However, the instant construction works need to be performed by black construction and luminous replacement works (hereinafter “instant construction works”).

) Since the instant construction work was part of the said construction work, the instant construction work cost is the same as before the former Income Tax Act (amended by Act No. 14389, Dec. 20, 2016; hereinafter the same applies).

Article 97(5) of the former Enforcement Decree of the Income Tax Act (Amended by Presidential Decree No. 26067, Feb. 3, 2015; Presidential Decree No. 26067, Feb. 2, 201)

The same shall apply to the part of paragraph

(2) Among the construction cost of this case, the part corresponding to the Plaintiff’s co-ownership should be included in the necessary expenses. (2) Capital expenses included in the necessary expenses to be deducted from the transfer value refers to the expenses to extend the lifespan of transferred assets or to increase the real value of transferred assets, and are included in the necessary expenses.