The judgment below is reversed, and the case is remanded to the Seoul High Court.

The grounds of appeal are examined.

1. A. Article 8-2(1) of the Act on the Aggravated Punishment, etc. of Specific Crimes (hereinafter “the instant provision”) provides that a person who commits a crime under Article 10(3) and the former part of Article 10(4) of the Punishment of Tax Evaders Act for profit shall be punished by imprisonment with prison labor for not less than three years, if the sum of the supplied values or the purchase values entered in the aggregate of the aggregate of the tax invoices on the tax invoices and the invoice for the purchase price of each seller is five billion won or more (hereinafter “supply price, etc.”) and the aggregate of the supplied values or purchase amounts entered in the aggregate of the aggregate of the tax invoices for each purchaser’s tax invoice and invoice for the purpose of profit-making (Article 10(2)2).

In light of the legal provisions of this case, the legal provisions of this case can be evaluated as a violation of one of the legal provisions of this case, such as where each violation of Article 10(3) of the Punishment of Tax Evaders Act continues to be committed for a certain period under the single and continuous criminal intent and where the act is deemed to have a temporary relationship between the act and the act, and where all of the supply values, etc. stated in the document corresponding to the act are deemed to be identical to the amount stipulated in the legal provisions of this case, a crime of violation of Article 10(1) of this case can be established by comprehensively covering the act (see Supreme Court Decision 2015Do2207, Jun. 23, 2015).