1. The defendant's appeal is dismissed.

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

Purport of claim and appeal

1...

1. The reasoning of the judgment of the court of first instance is as follows, except for the addition of some contents, and thus, it is consistent with the reasoning of the judgment of the court of first instance. Thus, it shall be cited in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article

The following shall be added to the sixth 18th of the judgment of the first instance.

3) In rendering the instant disposition, the Defendant asserts that, inasmuch as the Plaintiff’s representative director’s provisional payment amounting to KRW 330,000,000, which was used by the Plaintiff’s representative director, was included in the gross income and the corporate tax was revised accordingly, the Plaintiff’s transfer of the instant golf membership to the gross income should not be revoked even if the instant disposition was revoked on the ground that it was not the accord and satisfaction but the transfer of the instant golf membership was a transfer for security.

The plaintiff's transfer of a title to golf membership of this case in his name is not a payment in kind, but a transfer of a security for transfer is not a payment in kind, and according to the purport of the whole pleadings, the plaintiff has incurred losses (-2,298, 211, 220 won) in the business year 2012, and even if the representative director of the plaintiff's representative is recognized as the amount paid and KRW 330 million is included in the gross income, there is no corporate tax.

In other words, in the disposition of this case, even if the defendant excluded only KRW 12,834,684,934,935, which was included in gross income by deeming that the golf membership of this case was acquired as a substitute payment, from the total amount of KRW 12,834,684,935 and the representative director's provisional payment amount of KRW 330,00,00 (total amount of KRW 13,164,684,935), the disposition of this case should be revoked.

This part of the Defendant’s assertion is without merit to further examine.

A person shall be appointed.

2. If so, the plaintiff's claim should be quoted on the ground of its reasoning, and the judgment of the court of first instance is just in conclusion.