The part against the defendant shall be reversed.

Defendant shall be punished by a fine of KRW 65,000,000.

2. Prior to the determination of the Defendant’s assertion of unfair sentencing, the meaning of the language and text of Article 20 of the Punishment of Tax Evaders Act provides that “No restriction on the concurrence of fines under Article 38(1)2 of the Criminal Act shall apply to a person who commits an offense under Article 10 of the Punishment of Tax Evaders Act,” shall be construed to the effect that, in punishing a number of offenses on which judgment has not become final and conclusive simultaneously, the method of imposing a single punishment by increasing the maximum amount of fines under the main sentence of Article 38(1)2 of the Criminal Act shall not apply.”

Therefore, in the event that a fine is imposed on the crime of violation of the Punishment of Tax Offenses Act due to each of the above offenses at the same time, the fine should be separately imposed for each of the offenses and sentenced to a fine in total.

(2) In the case of this case where a public prosecution was instituted against a violation of Article 18 or 10(1)1 of the Punishment of Tax Evaders Act, the court below imposed a fine of 70 million won for all of the crimes without further proceeding to impose a fine for each of the crimes, while the court below imposed a fine for the violation of the Punishment of Tax Evaders Act on the part of the defendant for the violation of Article 18 or 10(1)1 of the Punishment of Tax Evaders Act.

In light of the above legal principles, the judgment of the court below is erroneous in the misunderstanding of legal principles under Article 20 of the Punishment of Tax Evaders Act, which affected the conclusion of the judgment.

3. Accordingly, the judgment of the court below is without a further determination on the defendant's assertion of unfair sentencing, on the grounds of the above ex officio reversal.