2. Determination

A. It is recognized that the Defendant led to the confession and reflect of the instant crime, and that the crime of fraud, which became final and conclusive in the judgment of the court below, and the crime of this case, are in the relation of concurrent crimes of a group after Article 37

B. However, in full view of the following circumstances: (a) submitting a list of total tax invoices, as seen in the instant crime, to the Government, as seen in the instant crime, disrupt the order of commercial transactions, seriously harmful to the national tax administration; (b) causing additional criminal acts by facilitating the creation of so-called non-financing; (c) the total sum of the tax invoices, which the Defendant submitted by false entries, exceeds KRW 2,660,950,000; (d) three previous criminal records of the same kind; and (e) other circumstances favorable to the Defendant, such as the Defendant’s age, background, and circumstances after the commission of the instant crime, the lower court’s punishment is too unreasonable, even if considering the above circumstances favorable to the Defendant.

Therefore, the defendant's above assertion is without merit.

3. In conclusion, the defendant's appeal is dismissed in accordance with Article 364 (4) of the Criminal Procedure Act on the grounds that the defendant's appeal is without merit. It is so decided as per Disposition.