A. The Defendant’s evaded tax amount of KRW 1,934,680,00, 1,934,680,000, should be deducted from the amount of the remaining sales proceeds excluding entrustment fees, out of the sales proceeds that the Defendant received by consignment from E, F, etc., but the lower court convicted all of the facts charged. In so doing, the lower court erred by misapprehending the rules of evidence,

B. The lower court’s sentencing is too unreasonable.

2. Determination

A. The following circumstances acknowledged by the court below based on the evidence duly adopted and examined by the court below as to the assertion of mistake of facts, etc.: ① the defendant did not dispute the amount of evaded tax of this case and the tax disposition against the defendant became final and conclusive; ② the defendant did not assert that he was entrusted with the amount of the sales proceeds from E, F, etc. by the investigation agency; ③ the witness I of the court below acknowledged all evaded tax amount; ③ the defendant was the same as the defendant's living together; ③ the witness I of the court below's witness who operated E was the vice president of D operated by the defendant did not explain the reason why he entrusted the amount of the sales proceeds to the defendant; the witness J of the court below stated that he was unable to find books related to the entrustment of the sales proceeds at the court of the court below; but, in light of the fact that the witness K of the court below, who operated F, was unable to present the documents related to the entrustment of the sales proceeds through the defendant's defense counsel; and in light of the fact that most of the receipts and promissory notes and the per unit number, it is difficult to believe that the defendant's statement.

B. The defendant's error in determining the argument of unfair sentencing is part of his/her own fault.