2. The defendants recognized the crime of this case, and the defendants did not have any profit from the crime of this case, and the defendants A did not have any criminal record for the same kind of crime and did not have any criminal record exceeding the fine, etc. are favorable circumstances.

On the other hand, the sum of supply values of false tax invoices issued or received by Defendant A exceeds KRW 1.77 billion, and the crime of this case is a crime that interferes with the legitimate exercise of the State’s right to tax collection, thereby impairing the tax justice and tax order, and is not good, and the crime of this case does not pay KRW 40 million of penalty tax imposed by the crime of this case.

There is no special relationship or change of circumstances that can be newly considered in the trial, and Defendant B is punished in accordance with the joint penal provisions due to the violation of the Punishment of Tax Evaders Act by Defendant A, the representative director of the company, and taking full account of the following: Defendant A’s age, character and conduct, family relation, circumstances after the crime, and various sentencing conditions as shown in the records and arguments of this case, such as the circumstances after the crime, it is difficult for the lower court’s

The Defendants’ assertion is not accepted.

3. As such, the Defendants’ appeal is without merit, and all of them are dismissed in accordance with Article 364(4) of the Criminal Procedure Act. It is so decided as per Disposition.