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 grounds for the court’s explanation concerning this case are as follows. The income tax shall be annually based on the 4th judgment of the first instance court and the 13th judgment of the second instance.

1. Inasmuch as the so-called “fixed-term taxation” imposing tax on the income amount for one year from January 1 to December 31, 199, in order to impose interest income accrued from non-business loans on global income tax base, the receipt date of such interest income needs to be specified. Thus, in order to regard the receipt date of the interest income as the “date of payment of interest under an agreement” as the “date of payment of interest pursuant to an agreement” under Article 45 subparagraph 9-2 of the Enforcement Decree of the Income Tax Act, the payment date of such interest income must be specified in the agreement to

(See Supreme Court Decision 2008Du6875 Decided March 12, 2009). Inasmuch as “The 14th Agreement” is the same as the statement in the reasoning of the judgment of the first instance except for the addition of “the express or implied” in the following cases, it shall be quoted in accordance with Article 8(2) of the Administrative Litigation Act and the main text of Article 420 of the Civil Procedure Act.

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