1. The plaintiff's appeal is dismissed.

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

The purport of the claim and the purport of the appeal shall be the first instance.

1. The reasoning of the judgment of this court for the acceptance of the judgment of the first instance is the same as that of the judgment of the first instance, except for the dismissal of the Plaintiff or the addition of the judgment on the Plaintiff’s new assertion, and thus, it is acceptable 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 annual annual amount of development expenses between the two years immediately preceding the decision of the first instance: the amount calculated for eight months in total among the annual average amount of research development expenses between the plaintiff's two years immediately preceding division, the 11 to 12, the 3rd 1721, the 21 to 4th 3rd 1, the 4th 4th 1st 4th 1), the 123th 7th 1, the 7th 11th 9th 11th 5th 5th 8 through 13 of the Special Cases concerning Taxation Act (the "Special Cases concerning Taxation" 8 through 13th 5th 5th 5th 5th 5th 5th 5th 2 years of the decision of the first instance court: the amount calculated for two years immediately preceding the division between the plaintiff's two years immediately preceding the division (the total amount of research development expenses between the plaintiff's two years preceding the previous year 2nd 2/12th 2th 2th of the previous year development expenses);

3. The addition;

A. The main point of the Plaintiff’s assertion has strictly interpreted the language and text of Article 9(6) of the former Enforcement Decree of the Restriction on Special Taxation Act, and “The difference between the research development cost of each business year that belongs to the divided corporation and the research development cost of each business year, which belongs to the divided corporation, is the research development cost that belongs to the divided corporation.

Article 9(6) of the former Enforcement Decree of the Act on Special Cases concerning Taxation (amended by the National Tax Service Act; -589, August 19, 2011; -627, May 30, 2013; - the Daejeon High Court Decision 2016Nu1146 Decided September 1, 201) by interpreting the purport to the effect that the tax authority externally indicated the interpretation of the taxation authority regarding the method of application of Article 9(6) of the former Enforcement Decree of the Act on Special Cases concerning Taxation (see, e.g., Supreme Court Decision 589, Aug. 19, 201; -627, May 30, 2013; and the Daejeon High Court Decision 201