A shall be punished by a fine of KRW 20,000,00,000,00 for six months of imprisonment for Defendant B.

However, Defendant A.

Defendant

A is the representative director of corporation B located in Seocho-gu Seoul Metropolitan Government F3, and Defendant B (the representative director A; hereinafter “Defendant Company”) is a corporation established for the purpose of household wholesale and retail business.

1. On December 18, 2011, Defendant A in violation of the Punishment of Tax Evaders Act of Defendant A issued 197 copies of the false tax invoice amounting to KRW 6,236,821,748 in total, from the time on December 31, 2015, including the issuance of one copy of the false tax invoice as if he/she supplied goods or services equivalent to KRW 16,40,00 in G, even though he/she did not supply goods or services.

2. From December 18, 2011 to December 31, 2015, Defendant Company violated the Punishment of Tax Evaders Act of Defendant Company, the representative director of Defendant Company, issued a Chapter 196 note of false tax invoice amounting to KRW 6,218,821,748 in total over 196 times as stated in paragraph 1 in the second column of attached Table 1 (excluding the transaction with H on December 31, 2011, listed in the second column of attached Table 1) with respect to the business of Defendant Company.

Summary of Evidence

1. Defendant A’s legal statement

1. Each prosecutor's statement concerning I, J, K, L, M, N,O, and P;

1. B A list of value-added tax returns and sales purchase tax invoices, copies of electronic tax invoices, Q of Tax Investigation Officers' Certificates, documents of the first revised return of value-added tax, documents of the second revised return of value-added tax, and notification of the results of tax investigation;

1. Relevant Article of the Act and the choice of punishment for the crime;

(a) Defendant A: Article 10(3)1 of the former Punishment of Tax Evaders Act (Amended by Act No. 11210, Jan. 26, 2012); Article 10(3)1 of the Punishment of Tax Evaders Act (amended by Act No. 11210, Jan. 26, 2012; hereinafter “former part of the crime”); Article 10(3)1 of the Punishment of Tax Evaders Act (amended by Act No. 11216, Jan. 26, 2012; elective of imprisonment);

B. Defendant Company: Article 18 of the Punishment of Tax Evaders Act, and the former Punishment of Tax Evaders Act (Act No. 1124, Jan. 26, 2012)