The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. As to the ground of appeal No. 4, Article 3(3)5 of the Corporate Tax Act provides that “the income generated from the disposal of fixed assets” as one of the income generated from the profit-making business of a nonprofit corporation shall be excluded from “the income generated from the disposal of fixed assets.”

Article 2(2) main sentence of the former Enforcement Decree of the Corporate Tax Act (amended by Presidential Decree No. 23589, Feb. 2, 2012; hereinafter the same) upon delegation (hereinafter “Enforcement Decree provision”) provides that “the term “the term “the term “the term “the term “the term “the term “the term” in this case” prescribed by Presidential Decree”)” as “the term “the term “the term “the term “the term “the term “the term “the term

citing the reasoning of the first instance judgment, the lower court determined that the provision of this case limits the scope of non-taxation subject to the delegation of Article 3(3)5 of the Corporate Tax Act based on reasonable standards, and that the provision is within the scope sufficiently predicted by delegation of the aforementioned legal provision, and thus, it cannot be deemed that the provision violates the principle of equality or the principle of substantial taxation, or goes beyond the bounds of delegation of the mother law.

Examining the foregoing provisions and relevant legal principles, the lower court’s aforementioned determination is justifiable.

In so doing, the lower court did not err by misapprehending the legal doctrine on the validity of the instant provision.

2. As to the ground of appeal No. 3, Article 3 (3) 5 of the Corporate Tax Act and the Enforcement Decree of the instant case concerning revenues arising from the disposal of fixed assets not directly used for proper purpose business for not less than three consecutive years as of the date of disposal of fixed assets by a nonprofit domestic corporation