All appeals by the Defendants are dismissed.

1. Summary of grounds for appeal;

A. Defendant A1) misunderstanding of facts in collusion with Defendant B and G, without Defendant A’s permission, issued the instant electronic tax invoice, and Defendant A did not participate at all. (2) The sentence imposed by the lower court of unreasonable sentencing (7 million won of fine) is too unreasonable.

B. Defendant B’s punishment (a fine of five million won) sentenced by the lower court is too unreasonable.

2. Determination

A. The evidence duly adopted and examined by the lower court regarding Defendant A’s assertion of mistake of facts and the following circumstances recognized thereby: (i) Defendant A, along with G and I, began to jointly operate the company F, which is the manufacturer company in the Kenya (hereinafter “instant company”); (ii) Defendant A invested KRW 50 million in the process of acquiring the company, and was appointed as an auditor on September 15, 201, and was appointed as the representative director on September 26, 201; (iii) was in charge of the production, etc. of Switzerland; (iv) was in charge of the business of operating the company, such as business and raising funds; (iv) was in charge of the business of operating the company after the acquisition of the electronic tax invoices in the name of the representative director at the time of operating the company; and (v) was subject to the change of the term of validity of the company’s electronic tax invoices issued under the name of the representative director at the time of issuing the company; and (v) was subject to the change of the term of validity of the company’s electronic tax invoices issued under the name.