The meaning of losses under the Corporate Tax Act

The total amount of losses exceeds the total amount of gains shall be all amounts of losses under the Corporate Tax Act, and only the amount investigated as losses at the time of final tax return or investigation and determination shall not be deemed to constitute losses.

Article 13 of the Corporate Tax Act

Article 10 of the Corporate Tax Act

The appeal is dismissed.

The costs of appeal are assessed against the defendant.

Although all of the records of this case and the judgment of the court below and the grounds of appeal were examined, the argument on the grounds of appeal by the appellant falls under Article 4 of the Act on Special Cases Concerning the Procedure of Appeal, and therefore, the appeal is dismissed under Article 5 of the same Act. It is so decided as