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.

1. The reasoning of the judgment of the court of first instance, such as admitting the judgment, is the same as the reasoning of the judgment of the court of first instance, except to supplement or add the judgment as follows 2. Thus, it shall be cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and the main sentence of Article

2. The supplementary and additional Plaintiff asserts to the effect that the instant disposition based on the corporate books that did not reflect the window dressing accounting was unlawful since the instant corporation excessively appropriated inventory assets from 2008 to 2011 and omitted retirement benefit appropriation liabilities.

As recognized by the first instance judgment cited by this Court, the burden of proving the net asset value is, in principle, to the tax authority, or in calculating the net asset value of the corporation as of the date of transfer, there are circumstances different from the statement of financial position of the corporation in calculating the net asset value.

exceptional circumstances, such as doing or doing, are against taxpayers who are dissatisfied with such circumstances.

The evidence submitted by the Plaintiff alone is insufficient to recognize that the corporation of this case was engaged in the window dressing accounting as alleged by the Plaintiff, and there is no other evidence to acknowledge it.

The plaintiff's assertion is without merit.

3. In conclusion, the plaintiff's claim shall be dismissed as it is without merit.

The judgment of the court of first instance with the same conclusion is just, and the plaintiff's appeal is dismissed as it is without merit.