1. The judgment below is reversed.

2. The defendant shall be punished by imprisonment with prison labor for a period of five and half years;

The defendant's KRW 4.3 billion is KRW 12.5 million.

In the process of a lawsuit and the process of the trial of this court, the prosecutor prosecuted the defendant against the violation of the law of defense and the violation of the Punishment of Tax Evaders Act, and the judgment of the court below found the defendant guilty of all the charges, and sentenced the defendant to a collection of 4.5 billion won due to the violation of the law of defense and defense.

Accordingly, the Defendant appealed on the grounds of mistake of facts, misunderstanding of legal principles, and illegality of sentencing, and the Prosecutor appealed on the grounds of unfair sentencing. Prior to the remanding of the judgment below, the Prosecutor reversed the part concerning additional collection among the judgment below and ordered to collect only KRW 4.31 billion.2.5 million, the Defendant dismissed all the Defendant’s mistake of facts, misunderstanding of legal principles, and misunderstanding of sentencing and the prosecutor’s unfair assertion of sentencing, and dismissed appeal.

Accordingly, the Defendant only convicted and collected 4.312 billion won on the ground of misunderstanding of facts and misunderstanding of legal principles (the first instance judgment prior to remand did not appeal against the part of the judgment of the court below which collected 4.31 billion won out of 4.5 billion won and rejected the remainder of 187.5 million won out of 4.5 billion won). The Supreme Court accepted only the Defendant’s appeal as to the part of the violation of the Punishment of Tax Offenses Act (the part of the second half-year value tax evasion in 2015, relating to the fees received from I), and rejected all the grounds for appeal as to the remainder of conviction and the additional collection in accordance with the violation of the Act on the Punishment of Tax Offenses and Defense, and reversed the remainder of conviction with the part of the above crime of violating the Punishment of Tax Offenses Act and the part of the remaining conviction with concurrent crimes under the former part of Article 37 of the Criminal Act and remanded to this court.

In the judgment of the court prior to the remanding of the scope of the trial, the part of the judgment of the court against the violation of the Punishment of Tax Offenses Act and the part of the judgment against the violation of the Act on Punishment of Tax Evaders and the violation of the Act on Punishment of Tax Evaders, excluding the part of the above part of the Punishment of Tax Offenses, and the part of 4.312.5 billion won, are rejected by the Supreme Court