The Defendants’ appeal is dismissed.

Summary of Grounds for Appeal

Each sentence of the lower court against the Defendants (each fine of KRW 15 million) is too unreasonable.

Judgment

Defendant

A has no record of punishment for the same kind of crime, and others are favorable circumstances.

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 not be deemed to be less restrictive to the liability for the crime of this case by encouraging so-called non-data transaction, thereby impairing the order of sound commercial transactions. In full view of the unfavorable circumstances, such as the total value of the total tax invoice by customer, entered by the Defendants without being supplied goods or services, exceeds KRW 380 million, and other factors of sentencing indicated in the records of this case, such as the Defendants’ environment, motive and circumstance of the crime, and circumstances after the crime, the sentence of the court below cannot be deemed to be too unreasonable

Therefore, the Defendants’ assertion of unreasonable sentencing is without merit.

Thus, the defendants' appeal is dismissed in accordance with Article 364 (4) of the Criminal Procedure Act since it is not reasonable.