2. The following are circumstances that are favorable to the Defendant: (a) the Defendant appears to have committed the instant crime from the investigative agency to the point that the Defendant was aware of all the instant crimes; (b) there is no benefit that the Defendant directly acquired by the instant crime, or appears to be minor; (c) there is no record that the Defendant was punished for the same type of crime; (d) there is no evidence that the Defendant evaded taxes in connection with the account statement issued and delivered by the Defendant; (b) the rehabilitation procedure was commenced around January 21, 2009; (c) the Defendant was declared bankrupt on January 21, 2013; and (d) the instant crime was committed in a concurrent relationship between fraud, etc. for which the judgment became final and conclusive on November 6, 2010, and the latter part of Article 37 of the Criminal Act should be considered at the same time

However, the crime of this case was committed by issuing and delivering a false statement equivalent to KRW 3.3 billion as if the defendant did not have a real transaction even though there was a real transaction. The total amount of supply price of the false statement is not smaller than the total amount, and the act of delivering and receiving a false statement is at risk of seriously impairing the order of taxation and commercial trust, and thus the quality of the crime cannot be deemed to be less light. It is not limited to simply receiving a false statement delivered by E, the other party to the act of issuing a false tax invoice by the defendant, a limited liability company, which is the defendant, from the defendant, but also submitted a false list of total tax invoices when filing a value-added tax return with the tax authority. As a result, the F and limited liability company E were punished, thereby using a false statement issued and issued by the defendant as a means of tax evasion. The crime of this case did not refuse a request