The defendant's appeal is dismissed.

The costs of lawsuit by the court below shall be borne by the defendant.

The decision of the court below on the gist of the defendant's appeal is that it constitutes a violation of the law and which affected the judgment, and it constitutes a mistake of fact that affects the conclusion of the judgment.

The punishment prescribed by the court of the court below (200 million won) is too unreasonable because it is too unreasonable.

The lower court’s judgment on the misunderstanding of the facts and misapprehension of the legal doctrine as to the misunderstanding of the facts stated in paragraph (1) of the facts charged, based on the prosecutor’s evidence, such as the list of items 1(1) below, recognized the contents of the testimony and documents, and comprehensively taking into account these facts, the prosecutor

On the basis of the facts charged of tax evasion: Summary of evidence

1. Legal statement of witness K or L;

1. The witness M’s 2nd and 10th trial date, each of the legal statements (the witness was only aware of this case’s tax audit conducted by the National Tax Service; the witness was not informed of this case’s tax audit conducted by the Defendant Company; and the Defendant Company’s tax affairs were entrusted to N in the office chief.

A witness made the N to prepare a document on the background of his disciplinary action according to the excessive appropriation of the purchase, and submitted it to the National Tax Service by affixing a seal on a written statement prepared by N.

1. Part of theO’s legal statement (a witness shall be a staff member of M certified tax accountant office, and a draft on which the purchase sales data received from the Defendant Company was electronically entered to the N office manager, and the N office manager instructed N to additionally enter the purchase by N, and the purchase cost was excessive without documentary evidence as to the part ordered);

1. A copy of M's statement (a certified tax accountant who is a delegated tax accountant under a tax agency contract shall not refuse the request of the delegated taxpayer, and N shall confirm the excessive appropriation of the purchase in the course of keeping a tax account book, and notify the defendant company of the fact that it is a tax payer and take measures;