2. In light of the contents, method, and result, etc. of the crime of this case committed by the Defendants without any real transaction and disturbing the order of commercial transactions, causing serious harm to the national tax administration, etc., the crime of this case was not committed, and the amount of value-added tax imposed in relation to the crime of this case has not been paid until 3 years since it was committed, and the total amount of false sales and purchases of this case exceeds KRW 1.647 billion, which is disadvantageous to the Defendants.

However, the defendants made statements that the crime of this case was led to the confession of the crime of this case and the violation of their depth, the crime of this case was not deemed to have been committed for profit-making purposes in a systematic and planned manner (no evidence exists to deem the crime of this case) and the purpose of tax evasion was not clearly presumed to have been committed, the business place of this case operated by the defendants is virtually discontinued, and thus there seems to be less likely to repeat the crime of this case. There are some circumstances to consider the motive and circumstances of the crime of this case, there are no criminal records of the same kind, there are no family members, there are no other circumstances to consider the motive and circumstances of the crime of this case, and there are no other circumstances to deem that the suspended sentence of imprisonment was significantly unfair, taking into account the defendants' age, character and behavior, intelligence and environment, motive and consequence, means and consequence of the crime of this case, the circumstances, degree of participation, degree of participation, criminal record, family relation, health conditions, etc., the court below's decision of this case was proper and too unfair.