The defendant's appeal is dismissed.

1. The summary of the grounds for appeal (defendants) is too unreasonable that the lower court’s punishment (two years of imprisonment, a fine of KRW 3150 million, and a fine of KRW 4.5 million per day for custody of conversion) is too unreasonable.

2. The judgment is favorable to the defendant, such as the fact that the defendant committed the crime of this case while intending to commit the crime of this case, and the defendant seems to have a relatively large profit from the actual acquisition due to the crime of this case. The substantial part in the crime of this case was accompanied by real transactions, and the fact that the defendant has no record of punishing the same kind of crime.

However, the crime of this case not only may interfere with the legitimate exercise of the State's right to tax collection, but also may disturb the sound order of commercial transactions by encouraging so-called non-data transactions. The total value of tax invoices issued or received by the defendant in falsity is 30.1 billion won, and the defendant seems to have led the crime of this case, and considering the overall circumstances of the defendant, the court below already sentenced the lowest sentence out of the scope of the recommended sentence according to the sentencing guidelines set by the Sentencing Commission of the Supreme Court in consideration of the defendant's overall circumstances, and other various sentencing conditions such as the defendant's age, character and behavior, environment, circumstances of the crime of this case, circumstances after the crime of this case, etc., it is not recognized that the

Therefore, the defendant's assertion is without merit.

3. As such, the defendant's appeal is without merit, and it is dismissed under Article 364 (4) of the Criminal Procedure Act. It is so decided as per Disposition.