The defendant's appeal is dismissed.

1. The summary of the grounds for appeal is that C does not issue a false tax invoice in the name of B, while C does not have a certificate of business registration issued by B registered as a business operator by C and E, and it does not have any consent to C and E to prepare a false value-added tax return in the name of B and submit it

Therefore, the defendant's complaint filed by C on the ground that C forged the defendant's seal impression and forged the value-added tax in the name of B is legitimate.

Nevertheless, the judgment of the court below which judged that the defendant was not guilty C is erroneous and has affected the conclusion of the judgment.

2. The judgment of the court below is consistent with the evidence duly adopted and examined as follows: ① The defendant created a business registration certificate with the name of "B", because he asked the defendant to "if the purchase data is insufficient, to issue the tax invoice"; ② the defendant's seal was not brought to B, issued the tax invoice of this case using the B's business registration certificate; ② E was investigated with the intent of forging and using the tax invoice of this case other than the violation of the Punishment of Tax Evaders Act by submitting the initial list of total tax invoices by misrepresentation; ② The investigation was conducted with the suspicion of violating the Punishment of Tax Evaders Act; ② the suspicion of forging and uttering the above investigation document was prosecuted only for the suspicion of violating the Punishment of Tax Evaders Act; ③ the defendant was subject to a disposition of suspicion on the grounds that the defendant implied consent was issued; ③ the defendant appeared to be the witness of this case; and thus, the defendant appeared to be the actual witness of this case.