The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined.

Article 21 (1) 17 of the Income Tax Act refers to money and valuables provided as a means of a case in connection with administrative affairs or provision of services, etc., and whether it constitutes such money and valuables must be determined by comprehensively considering the motive and purpose of receiving the money and valuables, relationship with the other party, amount, etc.

(see, e.g., Supreme Court Decision 2010Du27288, Sept. 13, 2013). The reasons in a written judgment include a judgment on the party’s allegations and other means of offence and defense to the extent that it can be recognized that the text is justifiable, and there is no need to determine all of the parties’ allegations or means of offence and defense.

(2) Article 208 of the Civil Procedure Act provides that “The omission of a judgment shall not be deemed to constitute an omission of a judgment, even if there is no direct determination as to the matters alleged by the parties to the judgment in the court.” Therefore, even if the court did not directly indicate the specific determination as to the matters alleged by the parties to the judgment, the omission of a judgment cannot be deemed to have been made if it can be known that the assertion was cited or rejected in light of the overall

(see, e.g., Supreme Court Decisions 2006Da218, Jul. 10, 2008; 201Da87174, Apr. 26, 2012). On the grounds indicated in its reasoning, the lower court determined that the instant protocol payment was lawful on the premise that the instant protocol payment was an honorarium for the purchase of alcoholic beverages by an importer-distributor of alcoholic beverages in its holding at a entertainment establishment.

The judgment below

Examining the reasoning in light of the aforementioned legal principles and the records, including the evidence duly admitted, the lower court’s conclusion is acceptable, even if there are some inappropriate parts in its reasoning.