2. In a case where there is no change in the conditions of sentencing compared with the first instance court, and where the sentencing of the first instance does not deviate from the reasonable scope of discretion, it is reasonable to respect such a case (see Supreme Court Decision 2015Do3260, Jul. 23, 2015). In the first instance court, there is no change in the conditions of sentencing compared with the lower court’s failure to submit new sentencing data, and the circumstances alleged by the Defendants for unfair reasons for sentencing are deemed to have already been reflected in the sentencing reasons of the lower court. The crime of this case is deemed to have already been issued or received a false tax invoice of approximately KRW 1.5 billion in total supply for about one year without supplying the goods, and its nature is not good. Such crime not only causes interference with the State’s tax collection function, but also is likely to undermine the sound tax order and good order by encouraging so-called non-data trading, which may cause harm to the general public’s awareness of compliance with the duty to pay taxes, and there is no possibility to view the circumstances of punishment of Defendant A beyond the age limit, motive and scope of criminal sentencing.

Therefore, the Defendants’ assertion is without merit.

3. In conclusion, the Defendants’ appeal is dismissed in accordance with Article 364(4) of the Criminal Procedure Act on the grounds that the Defendants’ appeal is without merit. It is so decided as per Disposition.