2. The first-class offender who did not have any record of committing any crime, or the first-class offender who did not have any record of committing any crime, or the first-class offender who did not have any record of committing the crime of this case where the sum of the amount of tax unlawfully deducted by the transaction partner, such as metal, etc. exceeds 38 million won due to the crime of this case, and there is no evidence to prove that the Defendant or other accomplices paid the amount of tax unfairly deducted as above. In full view of all other circumstances, the sentence of the lower judgment cannot be deemed unfair because the sentence of the lower court is too excessive, considering the following circumstances and contents of the crime of this case, including the Defendant’s age, character and conduct, family relation, environment, occupation, etc.

3. The defendant's appeal is dismissed in accordance with Article 364 (4) of the Criminal Procedure Act since it is without merit. It is so decided as per Disposition.