The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The grounds of appeal are examined (to the extent of supplement in case of supplemental appellate briefs not timely filed).

1. Article 12-3 of the former Certified Tax Accountant Act (amended by Act No. 9348 of Jan. 30, 2009) provides that no certified tax accountant shall allow another person to provide tax agent services using his name or trade name, or lend his/her certificate of qualification or registration to another person. Article 22-2 (1) of the former Certified Tax Accountant Act (amended by Act No. 6837 of Dec. 30, 2002) provides that where a person violates Article 22-2 (1) of the former Certified Tax Accountant Act, he/she shall be punished by imprisonment for not more than one year or by a fine not exceeding 10 million won, and Article 6 (1) of the former Certified Tax Accountant Act (amended by Act No. 7032 of Dec. 31, 2003) provides that where a person who has passed a certified tax accountant qualification examination intends to commence tax agent services, he/she shall register his/her tax agent services with the Ministry of Finance and Economy register, and the purport of Article 20 (136) of the former Certified Tax Accountant Act.

In addition to these legislative intent, the act of providing tax agent services and lending the name of a third party without being qualified as a tax accountant is not only a criminal act subject to criminal punishment, but also a negative effect on the property rights of the people and the government's financial revenue.