The judgment of the court below is reversed.

Defendant

A. The imprisonment of one year and six months, the imprisonment of Defendant E with prison labor of three years, and the fine of one billion won.

Summary of Grounds for Appeal

A. Defendant E-1) The portion of the tax invoice issued by B to F [Article 1. A. (1) of the original criminal facts in the judgment] F was ordered by the “L” company in China at the end of November 2017, and accordingly entered into a product supply contract with B around December 5, 2017 to be supplied with the Macact to be exported to L. The F was intended to issue the Macact to be exported to B in advance after the review by the competent certified public accountant in the situation where it is planned to export Macact, and to issue the 3,758,938,800 won of the supply price from B in advance, and if the supply of goods is not scheduled as scheduled, the F attempted to issue the Macact (-) tax invoice to be issued by the “L” company in China at the end of November 2017. Accordingly, the remaining portion of the tax invoice executed by the Defendant 2 without any particular fault in the execution of the sentence of imprisonment of 9,000 won (excluding the remaining portion of the tax invoice).

B. Prosecutor 1) Although issuance and receipt of false tax invoices among various companies substantially controlled and operated by the same person, all of the tax invoices issued and received shall be deemed to constitute false tax invoices under Article 8-2 (1) of the Act on the Aggravated Punishment, etc. of Specific Crimes, the lower court erred by misapprehending the legal doctrine that only one tax invoice constitutes this and thereby acquitted the Defendants on the part of the facts charged. 2) The Defendant A sentenced by the lower court of unfair sentencing to the Defendants: one year and six months, suspension of execution, three years, and fine.