2. The lower court determined that Defendant A and B submitted a list of individual tax invoices containing false information to Defendants A and B, and the Defendants did not object to the refund of value added taxes. The Defendants overlap with the supply of tax invoices and the total amount of tax invoices by individual suppliers stating false information, Defendant A did not have any same criminal record, and Defendant B also did not have any specific criminal record other than fines on two occasions due to this type of crime. The instant crime was committed at the request of G, the Defendants issued false tax invoices at the request of G, and received false tax invoices from M and N as the purchase data were necessary. Furthermore, the Defendants submitted a list of total tax invoices by individual suppliers stating false information, which may interfere with the State’s legitimate exercise of tax collection rights, and disrupt sound trade order. The total amount of the supply of tax invoices issued or received by the Defendants by fraudulent means and the total amount of tax invoices by individual suppliers reaches KRW 1 billion, and the Defendants were also subject to punishment of Defendants A and NN’s false information, as if they were actually supplied by the Defendants’ tax office and NN.