2. The judgment of the court below was made in favor of the defendant, such as the confession of the crime of this case, the defendant was punished for the same crime, or there was no record of criminal punishment heavier than suspended execution, and the defendant contributed to society by life saving as a long-term industrial potential source. However, although the crime of this case was committed in favor of the defendant, it is highly poor that the defendant evaded value-added tax of about 1.2 billion won in the short term by means of closing a business for a certain period of time without filing a purchase report, and the crime of this case is highly poor in light of the law and contents of the crime. Since the amount of evaded tax by the crime of this case is considerably large, the defendant failed to pay the above evaded tax up to now, and the defendant is expected to continue to engage in iron business again through a person who lent funds to the defendant after the completion of the execution of the punishment of this case, considering that the defendant's personal information cannot be clarified by the former purchasing agency or D's business funds, it is highly doubtful that the sentencing guidelines and sentencing of the defendant cannot be clarified.

3. In conclusion, the defendant's appeal is without merit, and Article 364 of the Criminal Procedure Act is not reasonable.