A. Defendant A and B jointly and severally agreed on KRW 10,076,316,830 and KRW 77,502,400 out of the said money. < Amended by Act No. 12555, Aug. 8, 2014>

A. On June 2014, Defendant A and Defendant B: (a) issued false sales tax invoices to dormant corporations or processing corporations that do not engage in the long-term business; (b) applied for the refund of false value-added tax based on the false tax calculation statement received by the said dormant corporations or processing corporations; and (c) conspired to receive unfair value-added tax from the competent tax office by deceiving the corporate director of the competent tax office and the director of the property tax; and (d) conspired directly with and in sequence with the remaining Defendants, etc.

B. According to the above public offering, Defendant A and B shared the roles as follows. Defendant B registered as the representative in the name of N, a corporation that exists only in the form of M with the consent of M, and Defendant A issued a tax invoice of KRW 780,300,000 in total on three occasions with the supplier who is a dormant corporation and received N as a supplier, and then filed an application for the refund of value-added tax in the name of N on July 24, 2014 with the above false tax invoice connected to the national tax integrated system, and received the refund of value-added tax in the name of N on August 8, 2014 with the approval of the director of the corporate division of Seocheon Sejong Tax Office and the director of the corporate tax division by deceiving the director of the corporate division of the corporate division of the property and the director of the corporate tax division of the corporation tax division, and around August 8, 2014, Defendant A received the refund of value-added tax in the name of N, Inc.

C. Defendant A and B, who corrected the foregoing N to P, changed the name of its representative from M to Defendant B, issued a false tax invoice equivalent to a total of KRW 10,339,630,00 in the name of P in the same manner, and issued an application for the refund of value-added tax on five occasions from September 25, 2014 to January 23, 2015, and filed an application for the refund of value-added tax in the name of the same company on five occasions from September 25, 2014; and the refund amounting to KRW 6,520,00 on or around October 6, 2014; KRW 7,758,000; KRW 7,758,000 on or around November 7, 2014; and around December 3, 2014; and around January 9, 2015.