For the reasons indicated in its holding, the lower court determined that all of the facts charged of this case is guilty and ordered the collection of the amount determined by the Defendant.

The judgment below

Examining the evidence duly admitted by the first instance court, the lower court did not err by exceeding the bounds of the principle of free evaluation of evidence against logical and empirical rules, or by misapprehending the legal doctrine on additional collection, contrary to what is alleged in the grounds of appeal.

Therefore, the appeal is dismissed. It is so decided as per Disposition by the assent of all participating Justices on the bench.