A defendant shall be punished by imprisonment for two years and by a fine of 840,000,000 won.

except that this judgment.

A. The sentence of the lower court against the Defendant (the imprisonment of two years, the suspension of the execution of the imprisonment of three years, the fine of 440 million won) is too unreasonable.

B. The lower court’s sentence against the Defendant by the Prosecutor is too unhued and unreasonable.

2. We examine ex officio prior to the determination of the ex officio judgment and the prosecutor’s improper assertion of sentencing.

Article 8(1) of the Act on the Aggravated Punishment, etc. of Specific Crimes (hereinafter “Aggravated Punishment of Specific Crimes”) provides for the aggravated punishment of a person who evades a tax, obtains a refund or deduction. Articles 3(1), 4, and 5 of the Punishment of Tax Evaders Act, and Article 102(1) of the Framework Act on Local Taxes provides that a person who commits a crime shall be punished by imprisonment with prison labor for life or for not less than five years, if the amount of tax evaded is at least one billion won per year for a person who commits a crime under Article 3(1), 4, and 5 of the Punishment of Tax Evaders Act, and Article 102(1) of the Framework Act on Local Tax, and by imprisonment with prison labor for not less than three years, if the amount of tax evaded is at least five hundred million won per year, but less than one billion won

Article 8-2 (1) 1 of the Act on the Aggravated Punishment of Specific Crimes provides that a person who commits a crime under Article 10 (3) and the former part of Article 10 (4) of the Punishment of Tax Evaders Act for profit shall be punished by imprisonment with prison labor for not less than three years, if the sum of the supply values entered in the list of the total tax invoices and the total of the purchase values, or the total of the purchase amounts, entered in the list of the total tax invoices of each purchaser and each purchaser's tax invoice (hereafter referred to as "total amount of supply values, etc." in this Article) exceeds five billion won, among persons who committed a crime under Article 10 (3) and the former part of Article 10 (4) of the Punishment of Tax Evaders Act for the purpose of profit-making, and a prosecutor institutes a public prosecution by applying Article 8-2

The court below acknowledged the fact that the defendant, in collusion with F, issued a false statement equivalent to the sum of KRW 4,010,510,000 in total as stated in paragraph (2) of the criminal facts in the judgment below, and submitted a false statement of total amount of KRW 4,070,538,000 to the Government, while the court below recognized the fact that the defendant submitted a false statement of total amount of KRW 4