(영문) 서울중앙지방법원 2018.9.7. 선고 2018고합147 판결

On September 8, 2016, the Defendant was sentenced to two years of imprisonment for violating the National Sports Promotion Act (Gambling, etc.) at the Seoul Central District Court on September 8, 2016 and the said judgment became final and conclusive on February 1, 2017.

The Defendant opened a private website called “E (F)”, which imitated D’s official website, which is a corporation B and C’s official website designated by the Korea Sports Promotion Foundation, from March 2015 to December 2015; G, H, etc., whose personal information cannot be identified by means of being deposited into an account in another person’s name without registering its business; 86% of equity interest; and the Defendant operated each illegal Internet gambling site at 14% of equity interest; and until July 27, 2015, the Defendant evaded the total amount of KRW 8,565,61 won in 205 to the competent tax office until January 25, 2016; and paid KRW 30,691,949; 369,949,936,9496,965,9636,964,965,965,965) by way of not reporting or paying it to the competent tax office until 25th, 2015.

Summary of Evidence

1. Partial statement of the defendant;

1. Legal statement of a witness I;

1. Partial statement of each prosecutor's protocol of examination of the defendant against the defendant;

1. Examination of suspect by the prosecution against I and J;

1. A copy of the investigation report (Attachment to the entry or departure status of each individual of the accused), analysis of the mobile phone text messages of the accused, output of a telegram, and output of a photograph of the contents of conversation with H;

1. Investigation report (Evidence attached to calculation of the amount of tax evaded on the illegal gambling site operated by the defendant), accusation, investigation report (Attachment to reference materials for calculation of the amount of tax evaded by the National Tax Service), details of safety account connected to the deposit account deposited by the gambling site users, and CDs;

1. Previous convictions: Court rulings and criminal records;

Application of Statutes

1. Article applicable to criminal facts;

Article 3(1) of the Punishment of Tax Evaders Act (amended by Act No. 14474, Dec. 27, 2016); Article 8(1)2 and (2) of the former Act on the Aggravated Punishment, etc. of Specific Crimes (amended by Act No. 14474, Dec. 27, 2016); Article 3(1) of the Punishment of Tax Evaders Act (the occupation of tax evasion in 2016, inclusive, the imposition of fines)

1. Handling concurrent crimes;

The latter part of Article 37 and the first sentence of Article 39 (1) of the Criminal Act

1. Reduction following the handling of concurrent crimes;

The latter part of Article 39(1) and Article 55(1)3 and 6 of the Criminal Act

1. Aggravation for concurrent crimes;

Article 37 (former part of Article 37, Article 38 (1) 2, and Article 50 (Concurrent Crimes within the scope of the sum of the long-term punishments of the crimes on the Aggravated Punishment, etc. of Specific Crimes (Tax) due to Tax Evasion in 2016) of the Criminal Act

1. Discretionary mitigation;

Articles 53 and 55(1)3 and 65(1)6 of the Criminal Act (The following extenuating circumstances among the reasons for sentencing):

1. Detention in a workhouse;

Articles 70 and 69(2) of the Criminal Act

Judgment on Defendant and Defense Counsel’s argument

1. Summary of the assertion

A. The site "E (F)" (hereinafter referred to as the "gamb site of this case") is not a site operated by a private B site that provides users with opportunities to participate in gambling by issuing and selling similar sports betting tickets, but a site that provides a kind of "private game with an opportunity to participate in gambling," which is operated by an operator and a user to participate in betting and acquiring property by betting and by means of a chance of winning. Thus, money deposited in the account of the Gambling site of this case is operated by a method of determining the acquisition and loss of property depending on a contingency or situation. Thus, it is not a site operated by the operator and a user to take property each other and determine the acquisition and loss of property in accordance with the circumstances and situation. Therefore, the money deposited in the account of the Gambling site of this case is merely an gambling and it is not subject to value-added tax (i.e., value-added tax).

B. The Defendant is not only a person who supplied a substitute passbook to be used on the instant gambling site, but also the Defendant acquired 14% of the shares in the instant gambling site. However, even though the Defendant intended to acquire 14% of the shares in the instant gambling site, it was formally acquired under the name of the head of the relevant Tong in the event of an accident caused by the passbook supplied as above, and did not obtain any benefit from the operation of the instant gambling site at all, and thus, it does not constitute a taxpayer who is the subject of tax evasion (ii).

2. Determination

(a) Facts of recognition;

According to the above evidence and the statement of evidence Nos. 5 through 8 submitted by the defendant, the following facts are acknowledged.

1) The instant gambling site is a private B site that imitates “D,” which is the official website of Company B and C, which is designated by the Korea Sports Promotion Foundation as the seller of sports promotion betting tickets, and the users deposited an amount of 10,000 won from 10,000 won per game deposit account (hereinafter referred to as “the instant charging account”) and predicted the outcome of sports games, such as camping-gu, farming-gu, farming-gu, distribution apparatus, stable, scambing, and nat, and the result was operated in a way to recover dividends (the investigative record No. 1 right 49,50, 163, 267, 268).

2) From March 2015 to December 2015, the Defendant supplied a large passbook to be used at the instant gambling site, and if the proceeds from the instant gambling site were deposited in the large passbook, he/she withdrawn it according to the instructions of one of the instant gambling site operators and delivered or distributed it to H or to the person designated by H (2-6 pages of the witness I’s examination record, 163, 165, 166 pages of the investigation record). In the process, the Defendant left the Republic of Korea from January 2015 to March 2016 under the direction of H on five occasions (14, 14, 165, 166 of the investigation record).

3) Meanwhile, the Defendant acquired 14% of the shares in the instant gambling site without any additional fund in return for the loss incurred therefrom (No. 165, 167, 168, 268 of the Investigation Records) where the nominal owner of the supply passbook arbitrarily withdraws the money deposited in the relevant passbook or prevents withdrawal of money by filing a report on an accident (hereinafter referred to as “accident in the passbook”).

B. Whether the value-added tax is imposed (i) whether it is subject to value-added tax

1) Relevant statutes

A person shall be appointed.

2) Relevant precedents

Value-added tax is imposed on the basis of value-added generated in all stages of production, provision, or distribution of goods or services. As such, value-added tax is a principle for imposing value-added tax on the distribution stage of goods or services that are newly created. Gambling is to determine the acquisition and loss of property by taking property among the participants and determining the acquisition and loss of property depending on the contingency or situation. Therefore, gambling is not a general creation of value-added tax, and it is not subject to value-added tax.

However, in the event that gambling business is conducted, if the customer’s money paid falls under the price for the goods or services provided by the business operator, not merely a money for gambling, it is subject to value-added tax. Therefore, in a case where a sports gambling business operator provides customers with an opportunity to participate in gambling and receives money as consideration for such offer through an information and communications network, even if the act promotes speculation, it constitutes a supply of goods or services with property value, and thus, it should be subject to value-added tax (see, e.g., Supreme Court Decision 2016Do19704, Apr. 7, 2017).

2) Specific determination

Examining the instant case in accordance with the relevant statutes and the relevant precedents, it is reasonable to view that the money deposited in the account of the instant gambling site is subject to value-added tax as the price for receiving opportunities to participate in gambling by purchasing similar sports betting tickets issued and sold on the instant gambling site, i.e., the price for receiving goods or services provided by the instant gambling site, in full view of the following circumstances acknowledged by the facts of recognition and the evidence revealed earlier. Accordingly, this part of the allegation by the Defendant and the defense counsel is rejected.

A) The instant gambling site was operated by issuing and selling similar sports betting tickets and paying and exchanging dividends to those who correctly predicted the outcome of sports games with financial resources.

B) The operator of the instant gambling site did not directly take property and participate in gambling with the purchaser of similar sports betting tickets, but only received the price for the issuance and sale of similar sports betting tickets, and only between the purchaser and the purchaser of similar sports betting tickets, the acquisition and loss of property was determined by the chance of being the hostile of the outcome of sports games.

C) The money paid for the purchase of similar sports betting tickets issued and sold on the instant gambling site shall be reverted to the operator of the instant gambling site immediately, and the payment of dividends to those who correctly predicted the outcome of sports games is paid, but the purchase price of similar sports betting tickets itself was not returned.

D) A purchaser of similar sports promotion betting tickets issued and sold on the instant gambling site can be seen as creating added value in this process by enjoying the outcome of sports games using the instant gambling site and paying the dividend to the purchaser.

E) The Defendant alleged that the instant gambling site is not a private B site, but a sort of “private bridge game,” which acquires the acquisition and loss of property by betting alone, even though the instant gambling site is a private B site, as seen earlier, it is difficult to recognize the instant gambling site as a “private bridge game,” solely on the written evidence Nos. 9 and 10 (including each number of numbers) submitted by the Defendant.

C. Whether the taxpayer is liable for duty payment (determination as to ② argument)

In full view of the following circumstances acknowledged by the above facts and the evidence revealed above, the Defendant jointly operated the instant gambling site with H et al. and recognized as a joint business owner under Article 25(1)4 of the Framework Act on National Taxes. Thus, the Defendant and the defense counsel’s assertion on this part cannot be accepted.

1) The Defendant frequently committed an essential role in the operation of the instant gambling site, such as the provision of an passbook to be used at the instant gambling site, and the withdrawal, delivery, or distribution of the money deposited in the said passbook. The Defendant himself stated to the effect that “the fact that he was involved in the first operation of the instant gambling site from the time when the instant gambling site begins (No. 163, 164 pages of the Investigation Records).”

2) The Defendant acquired 14% of the shares in the instant gambling site in return for the charge of the loss incurred in the event of an incident of passbook on his own supply, and accordingly, intended to receive 14% of the proceeds of the instant gambling site, not the fixed and regular pay (No. 167 pages of the Investigation Records).

3) Separate from receiving 14% of the proceeds of the instant gambling site, the Defendant, who was an employee of the instant gambling site, withdrawn the proceeds of the instant gambling site to I et al., and received 3% of the amount of withdrawal from the commission and used them as monthly pay to I et al. (21,22 pages of the witness I’s examination record).

4) Meanwhile, the Defendant stated to the effect that “the Defendant was unable to receive all the proceeds of the instant gambling site by having paid KRW 100 million or more losses due to the instant passbook accident” (Article 168 and 169 of the Investigation Record), and that “the Defendant was able to pay the proceeds of the instant gambling site due to the instant passbook accident,” and that “the Defendant was able to pay the proceeds of the instant gambling site up to KRW 1-200 million” (Article 11, 12, 15, and 16 of the Protocol on the Examination of Witnesses as to the Witness I). However, even if the Defendant was unable to receive the proceeds of the instant gambling site as stated above, it is difficult to view that the Defendant was merely a mere employee, as long as the Defendant incurred losses in the course of operating the instant gambling site, even if he was not able to receive the proceeds of the instant gambling site.

Reasons for sentencing

1. The scope of punishment by law;

(a) Imprisonment: From September to eight years;

(b) Fines: 448,452,171 won to KRW 1,121,130,428;

2. Scope of recommended sentences according to the sentencing criteria;

Sentencing is not applicable because the former and the latter concurrent crimes of Article 37 of the Criminal Act are concurrent crimes.

3. Determination of sentence;

The crime of this case is committed by the Defendant while operating the illegal B site, and thereby evading taxes because the Defendant did not return or pay value-added tax and income tax while receiving money for charging game money from the users. Such act of tax evasion may disrupt tax order by making it difficult for the State to impose and collect taxes, thereby causing damage to tax justice by exceeding the burden to the general public. As such, the crime liability is not easy, the total amount of tax evaded by the Defendant is not less than 90 million won, and the Defendant does not pay taxes evaded at all.

However, the crime of this case is a concurrent crime under the latter part of Article 37 of the Criminal Act with regard to a violation of the National Sports Promotion Act (Gambling, etc.), etc. for which judgment has become final and conclusive, taking into account the equity between the defendant and the concurrent crimes under the latter part of Article 37 of the Criminal Act. In the process of committing the crime of violating the National Sports Promotion Act (Gambing, etc.) rather than for the original purpose of tax evasion itself, the defendant is close to the crime of tax evasion; the defendant has been sentenced to imprisonment for a long time due to the crime of violating the National Sports Promotion Act (Gambing, etc.); the defendant's share and benefit level; the defendant has no record of being punished as a tax offense; the defendant's age, growth process, family relationship; the details and method of the crime; and the circumstances before

Parts of innocence

1. Summary of the facts charged

The Defendant opened a private site called “E (E)”, which imitated D’, which is an official Internet site of Company B and C, designated as the seller of sports promotion betting tickets, from March 25, 2015 to December 2015; G, H, etc., whose personal information cannot be identified by means of being deposited into an account in another person’s name without registering its business; and the Defendant operated each illegal Internet gambling site by designating 14% of equity; the Defendant, by not later than July 27, 2015, evaded value-added tax 31,039,455 won for 205 to 31,039,455 won for 2015 to 202,329,362,526,428, 205 to 36.5,65 to 205 to 36.65,205 to 206,516,536,206.

2. Defendant and his defense counsel’s assertion

Inasmuch as there is no evidence to prove that the Defendant received the instant gambling money in excess of the amount in the separate sheet “amount of money deposited” from the gambling site users, this part of the facts charged cannot be recognized that the Defendant additionally evaded KRW 31,039,45 as value-added tax for the first year of 2015, KRW 2,392,564 as value-added tax for the second year of 2015, and KRW 153,963,898 as income tax for the year 2015.

3. Determination

(a) Facts of recognition;

According to the evidence mentioned above, it is recognized that the Do funds deposited into the instant charging account was deposited and deposited in the Do gold receipt account (the safety account; hereinafter referred to as the "safety account of this case") connected to the instant filling account, and the details of the safety account connected to the instant filling account and the total amount deposited into the safety account of this case are as follows.

A person shall be appointed.

B. Specific determination

Of the attached table, it is necessary to examine whether the total amount of the instant safety account was deposited by the instant gambling site users in excess of the amount of money in excess of the amount of money in the “passing” column by each safety account (However, in the case of the instant safety account, the fact that the total amount of the instant security account was deposited by the instant gambling site users, as seen earlier, is the maximum amount of money deposited by the instant gambling site users. Therefore, it is reasonable to examine only ten safety accounts other than the AE AC bank account).

1) In the case of MN account:

As seen earlier, insofar as the K Postal Account, U Postal Account, and AW Bank Account was connected to the MN account out of the instant safe account, it is difficult to recognize that the amount deposited from the K Postal Account, U Postal Account, and AW Bank Account out of the amount deposited to the MN account as the amount deposited from the other accounts than the K Postal Account, U Postal Account, and AW Bank Account was the intended amount deposited by the instant gambling site users, and there is no other evidence to acknowledge this differently.

However, according to the above facts and the above evidence, 167,654,50 won (=43,151,531 -275,497,031 won) excluding 275,497,031 won (i.e., KRW 443,151,531 -275,497,031 won) of the total amount deposited by the gambling site users of this case among the total amount of KRW 443,151,531, which was deposited by the gambling site users of this case to the MN account) is recognized as having been deposited by the K Post account and other accounts than the AW Bank account. Accordingly, it is difficult to recognize as having been deposited by the gambling site users of this case.

2) In the case of the P Enterprise Bank Account and the RS Bank Account:

As seen earlier, as long as the K Post Office Account, AW Bank Account, AY Bank Account, and AY Bank Account were linked to the P Enterprise Bank Account and RS Bank Account among the instant safe account, it is difficult to recognize that the amount deposited from each of the instant safe account, other than the K Enterprise Bank Account, AW Bank Account, and AY Bank Account, as the amount deposited from each of the instant safe account, is difficult to recognize as the intended amount deposited by the instant gambling site users, and there is no other evidence to acknowledge otherwise.

However, according to the above facts and the above evidence, among the maximum amount of KRW 8,814,969,00, which was deposited by the gambling site users of this case among the total amount of KRW 8,814,969,000, KRW 7,011,643,00 (= KRW 8,814,969,000 - 1,803,326,000) - 1,803,803,326,000) - 2,198,263,500, which was deposited by the gambling site users of this case, it is difficult to recognize that the amount of KRW 1,80,000, KRW 700, KRW 700, KRW 190,515,009 which was deposited by the gambling site users of this case, exceeds the amount of KRW 1,80,000, KRW 710,508,205,20500.

3) In the case of a WX account or ZB bank account:

As seen earlier, as long as the U postal account in the instant charging account was connected to WX and Z enterprise bank account among the instant safe account, it is difficult to recognize that the amount deposited from each other than the U Post account was the intended amount deposited by the instant gambling site users, and there is no other evidence to acknowledge otherwise.

However, according to the above facts and the above evidence, among the limit amount of KRW 822,638,50,00, WX’s total deposit amount of KRW 822,638,50,000 other than WX’s deposit amount of KRW 289,68,50,00 (= KRW 822,638,500, KRW 289,68,500) - - 289,68,500) - 3,981,07,000, the total deposit amount of the ZX’s bank’s account was deposited by ZB’s 3,981,07,00, 2,040, 307, 400, 407, 509, 307, 400, 500, 1300, 407, 507, 1000, 407, 3001.

4) In the case of MF AG bank account and W AI account:

As seen earlier, the AB AC bank account and the AE AC bank account in the instant filling account are the same account as 'AD'. Since the amount deposited from the AB AC bank account to the MF AG bank account and WAI account out of the instant safety account is the amount deposited from each of the instant safety account and transferred from the AE AC bank account, which is the other safety account, to the safety account. Thus, as long as the total amount deposited from the AE AC bank account is already included in the limit amount deposited by the instant gambling site users, it is difficult to recognize each of the above amounts in duplicate with the limit amount deposited by the instant gambling site users.

However, according to the above facts and the above evidence, 1,239,120,000 won (=262,02,900 won - 22,902,900 won - 22,900 won - 22,902,900 won - 162,900 won - 22,900 won) - W AI account’s total deposit amount of 1,320,520,000 won deposited by the gambling site user and 1,320,520,000 won deposited by the gambling site - 1,320,00 won deposited by the gambling site - 1,320,000 won deposited by the gambling site - 1,320,000 won deposited from the AF bank - 20,000 won deposited from the AF AF A bank - 1,300,000 won deposited from the AF bank -200,500,200

5) In the case of AK Enterprise Bank Account, AR X Account:

위 인정사실 및 앞서 든 증거들에 의하면, 이 사건 안전계좌 중 AK 기업은행 계좌에는 2015. 3. 30.부터 2015. 4. 2.까지 매일 연속적으로 입금이 이루어지다가 2015. 4. 3.부터 2015. 4. 29.까지 그 입금이 중단되었고, 2015. 4. 30.부터 다시 입금이 시작된 사실, AK 기업은행 계좌에 2015. 3. 30.부터 2015. 4. 2.까지 입금된 금액의 합계액은 80,181,161원19)이고, 2015. 4. 30.부터 2015. 11. 24.까지 입금된 금액의 합계액은 3,336,978,882원20)인 사실, 한편 이 사건 안전계좌 중 AR X 계좌에는 2015. 9. 21.부터 2015. 11. 5.까지 매일 연속적으로 입금이 이루어지다가 2015. 11. 6.부터 2015. 11. 8.까지 그 입금이 중단되었고, 2015. 11. 9.부터 다시 입금이 시작된 사실, AR X 계좌에 2015. 9. 21.부터 2015. 11. 5.까지 입금된 금액의 합계액은 2,411,059,000원21)이고, 2015. 11. 9.부터 2015. 12. 7.까지 입금된 금액의 합계액은 5,197,752,821원22)인 사실이 인정되는바, ① 도박사이트의 안전계좌는 단속 등을 피하기 위하여 2~3개월 정도 사용되다가 교체되는 것이 통상적인 점, ② 도박사이트의 안전계좌로 사용되다가 위와 같이 사용이 중단된 후 다시 같은 도박사이트의 안전계좌로 사용되는 것은 극히 이례적인 점, ③ 이 사건 도박사이트 직원인 I 역시 '대포통장을 1~2개월 정도 사용하고 바꿨다', '1~2개월 정도 사용하면 대포통장 명의자가 다른 도박사이트에 대포통장을 넘긴다', '대포통장을 실제 사용한 기간은 1~2개월 정도밖에 되지 않는다'는 취지로 각 진술하고 있는 점(증인 I에 대한 증인신문 녹취서 17, 18쪽) 등을 고려하면, AK 기업은행 계좌에 2015. 4. 30.부터 2015. 11. 24.까지 입금된 금액의 합계액 3,336,978,882원[AK 기업은행 계좌의 총 입금액 3,417,160,043원 중 이 사건 도박사이트 이용자들이 입금한 도금액으로서 AK 기업은행 계좌로 이체되어 보관 · 출금된 80,181,161원을 제외한 3,336,978,882원(= 3,417,160,043원 - 80,181,161원)과 같은 금액이다], AR X 계좌에 2015. 11. 9.부터 2015. 12. 7.까지 입금된 금액의 합계액 5,197,752,821원[AR X 계좌의 총 입금액 7,608,811,821원 중 이 사건 도박사이트 이용자들이 입금한 도금액으로서 AR X 계좌로 이체되어 보관· 출금된 2,411,059,000원을 제외한 5,197,752,821원(=7,608,811,821원 - 2,411,059,000원)과 같은 금액이다]은 이 사건 도박사이트 이용자들이 입금한 도금액이라고 인정하기 어렵고, 달리 이를 인정할 만한 증거가 없다.

6) In the case of AP Enterprise Bank Account:

As seen earlier, as long as the AMFN bank account was connected to the AP bank account among the instant charging accounts, it is difficult to recognize the amount deposited from the AP bank account other than the AMF bank account as the amount deposited from the AP bank account, and there is no other evidence to acknowledge otherwise.

However, according to the above facts and the above evidence, 4,008,32,000 won (=4,049,32,000 won - 41,010,000 won - 41,000 won - 41,000 won - 41,000 won -00 won - 41,010,000 won) was deposited in another account than the AP bank account. Thus, it is difficult to recognize that the above 4,008,32,000 won was the maximum amount deposited by the GP bank users.

7) Sub-committee

Therefore, it is difficult to recognize that the amount exceeding the amount of money in excess of the "amount of money deposited" column from the total amount of money deposited in the safety account of this case is the amount deposited by the gambling site users. Therefore, it is difficult to recognize each amount of tax evaded as stated in this part of the facts charged on the premise that the above amount of money exceeded is the amount of money deposited by the gambling site users.

4. Conclusion

Thus, this part of the facts charged should be pronounced not guilty pursuant to the latter part of Article 325 of the Criminal Procedure Act because it falls under the absence of proof of criminal facts. However, as long as it is found guilty of the violation of the Punishment of Tax Evaders Act and the violation of the Act on the Aggravated Punishment, etc. of Specific Crimes (tax)

Judges

The presiding judge, the Kim Jong-dong

Judge Political decoration

Judge Lee Sang-hoon

Note tin

1) Specific calculation details are as follows 1 in the column of ‘value-added tax evasion' in the attached Table.

2) Specific calculation details are as follows: ‘The amount of evaded value-added tax' column in the attached Table 2.

3) Specific calculation details are as shown in the column of "amount of evaded income tax" in the attached Table 3.

4) Article 25(Joint and Several Liability for Tax Payment) ① The liability for national taxes, surcharges, and expenses for disposition on default related to the property jointly owned, joint projects, or property belonging to such joint projects shall be jointly and severally liable to pay them.

5) It is the amount of entrance by the sequence 1 in the attached table.

6) Of the specifications of MN account (Evidence Nos. 70 and 71), the sum of the respective deposit amounts of Nos. 20-139, 144, 147, 148, 171, 181, and 184 is the aggregate of the deposit amounts.

7) It is the amount of entrance in the table Nos. 2 in the attached table.

8) Of the details of transactions in the P Enterprise Bank Account (Evidence No. 70, 71) (Evidence No. 70, 71), the sum of each deposit amount set forth in 1-25, 28-1026, 1028-1430, 801-1815.

9) Of the attached table, the amount of entrance by 3 is the amount in [Attachment Table].

10) R s은행 계좌의 거래내역(증 제70, 71호증) 중 순번 125~144, 146~962, 965, 966, 972~978, 981, 98z, 984, 987, 988, 991, 993, 994, 997, 1003, 1005, 1006, 1008~1012, 1014~1016, 1018, 1023, 1024, 1027, 1028, 1031~1035, 1038, 1040, 1043~1045, 1048, 1052, 1053, 1056, 1062, 1066~1068, 1070~1075, 1077~1079, 1083, 1086, 1087, 1091, 1095, 1098, 1100, 1101, 1103, 1106, 1111~1113, 1115, 1118, 1126, 1127, 1129, 1132~1135, 1137, 1138, 1141, 1143, 1151, 1155, 1158, 1160~1163, 1168, 1171, 1179, 1180, 1182~1186, 1188, 1193, 1194, 1198, 1199, 1201, 1202, 1206, 1207, 1209, 1211~1215, 1217, 1219, 1220, 1225, 1226, 1231, 1232, 1237, 1240, 1242, 1244, 1245, 1255, 1256, 1260, 1262, 1266, 1267, 1269, 1272, 1277, 1278, 1282, 1295, 1297, 1299, 1302, 1303, 1305, 1309, 1314, 1315, 1318, 1321, 1323, 1324, 1326, 1329, 1331~1344, 1346~1350, 1352~1357, 1359~1375, 1377~1428의 각 입금액의 합계액이다.

11) It is the amount of entrance by the sequence 4 in the attached Table.

12) Of the details of transactions in the RS bank account (Evidence Nos. 70 and 71), each of the deposited amounts is the sum of 2-284, 286, 288-290, 293-302.

13) It is the amount of entrance by sequence 5 in the attached table.

14) Z 기업은행 계좌의 거래내역(증 제70, 71호증) 중 순번 1, 6~11, 13, 14, 17, 22, 23, 36, 44~48, 50, 51, 56, 69, 73, 74, 78, 84~87, 99, 100, 103~105, 107~111, 123, 124, 118, 119, 133, 135, 138~142, 145~149, 152, 153, 156, 157, 159, 160, 162~164, 170, 171. 175, 197, 201~203, 205, 207~209, 211, 216~218, 220, 222, 223, 228, 244~249, 251, 252, 254~256, 263, 267~270, 274, 276, 291, 292, 296, 298, 300, 302, 306~311, 317, 321~328, 341, 343, 347, 350, 351, 353, 360, 361, 366, 367, 370, 374~376, 382, 384~387, 390~394, 396, 397, 399, 401, 407~410, 427, 430, 432, 434~438, 440~443, 446, 447, 449, 450, 464~466, 469~473, 477~479, 492, 493, 497~500, 502~508, 511, 513, 522, 534~539, 541~543, 550, 557, 567~570, 572~574, 578, 582, 585, 586, 615~618, 620, 622, 624, 625, 628~630, 633, 634, 636, 658, 659, 661, 662, 667~669, 677, 687~692, 697~700, 702, 717~725, 728~730, 734, 739, 751, 752, 755~769, 772, 774, 776, 786~791, 794, 796~798, 807, 810~815, 818, 819, 824, 847~851, 855~858, 860~866, 869, 871~876, 881, 886, 887, 891, 904~917, 919~933, 936, 938~942, 949, 950, 952~954, 956, 978, 986~992, 994, 995, 998~1001, 1003, 1005~1007, 1009~1015, 1017, 1019, 1021~1026, 1031~1039, 1043, 1051, 1072~1082, 1084, 1086, 1087, 1089, 1090, 1092~1101, 1104, 1106~1109, 1112~1114, 1121, 1122, 1124, 1126~1131, 1136, 1146, 1170~1173, 1176~1189, 1191, 1193~1200, 1202, 1204, 1205, 1207~1216, 1223~1230, 1235, 1238, 1259~1264, 1266~1269, 1275~1283, 1285~1301, 1303~1309, 1311~1313, 1325~1328, 1342, 1343, 1345~1349, 1351, 1353~1355, 1358~1370, 1376, 1377, 1379~1387, 1395~1399, 1404, 1423, 1429, 1432, 1433, 1435, 1437, 1440, 1443~1445, 1448, 1457, 1464, 1466~1468, 1478, 1481~1484, 1489~1492, 1494, 1495, 1500~1502, 1504~1514, 1517, 1522, 1525, 1527~1531, 1533, 1537, 1540, 1542, 1543, 1552~1561, 1565~1568, 1570, 1585~1595, 1598, 1603, 1604, 1608~1610, 1612~1614, 1629, 1631~1637, 1639~1644, 1648, 1649, 1654, 1655, 1661~1663, 1666~1669, 1671~1673, 1675, 1677, 1682, 1689~1697, 1699~1708, 1717~1722, 1725~1729, 1732~1741, 1743~1746, 1748, 1749, 1754~1758, 1779~1782, 1784~1787, 1798~1802, 1836~1843, 1851, 1875~1881, 1884, 1885, 1887, 1894, 1906, 1942, 1951, 1953, 1957, 1960~1967, 1969~1971, 1973, 1974, 1979, 1980, 1983~1987, 1989~1991, 1996, 2003, 2035, 2040, 2042, 2046, 2048, 2052, 2055, 2056, 2058, 2060, 2061, 2064, 2066~2068, 2071, 2119, 2121, 2122, 2124, 2128~2131, 2136, 2142, 2151, 2152, 2156, 2194~2196, 2198~2203, 2205~2211, 2213~2215, 2218, 2220~2226, 2229, 2230, 2232~2234, 2236~2240, 2243, 2246, 2248, 2250, 2253, 2272~2275, 2277~2284, 2288~2290, 2293, 2308, 2311~2317, 2319, 2323, 2325, 2328, 2329, 2331~2333, 2335~2337, 2339, 2354~2358, 2363~2367, 2369~2373, 2375~2378, 2380~2382, 2411, 2413~2420, 2422, 2423, 2425, 2428~2430, 2433, 2434, 2439~2441, 2444, 2446, 2447, 2449, 2450, 2465, 2471, 2473, 2474, 2476~2484, 2489~2492, 2494~2497, 2499~2501, 2503~2509, 2513~2518, 2525, 2528, 2529, 2533, 2546, 2547, 2549~2552, 2554~2556, 2558~2561, 2564~2567의 각 입금액의 합계액이다.

15) It is the amount of entrance by sequence 7 in the attached Table.

16) The sum of the respective amount deposited in MAF AG bank accounts (Evidence No. 70, 71) 92-526, 528-532.

17) It is the amount of entrance by sequence 8 in the attached Table.

18) The sum of the respective amount of money deposited between 2-128, 130-807 out of the details of transactions in the WAI account (Evidence No. 70, 71) is the aggregate.

19) It is the amount of entrance by the sequence 9 in the attached Table.

20) The sum of each deposit amount set forth in No. 344-13668, out of the specifications of transactions in AK Enterprise Bank Account (Evidence No. 70, 71).

21) It is the amount of entrance by the sequence 11 in the attached Table.

22) The sum of each deposit amount of AR X account No. 1122-3233 out of the transaction details (Evidence No. 70, 71) of ARX account is the aggregate.

23) It is the amount of entrance by 10 set forth in the attached Table 10.

24) Of the details of transactions in the AP Bank’s account (Evidence No. 70, 71), the sum of each deposit amount set forth in 1-37, 39, 43, 44, 46, 50-52, 56, 62, 65-73, 75, 76, 78, 81, 84-87, 89-11, 113-17, 119-121, 124-2089.

Attached Form

A person shall be appointed.