The appeal is dismissed.

The costs of appeal are assessed against the defendant.

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

1. As to the grounds of appeal Nos. 2 and 3

A. The so-called administrative rules, which are issued by a superior administrative agency to a subordinate administrative agency, are generally effective only within the administrative organization and do not have external binding force. However, if a provision of law does not specify the procedure or method of exercising its authority while granting the authority to determine the specific matters of the law to a specific administrative agency, and the delegated administrative agency specifically determines matters that are the contents of the law in the form of administrative rules, it shall not be a general effect of the administrative rules as seen above, but shall have the function to supplement the contents of the law in accordance with the provisions of the law that granted the authority to supplement the specific matters of the law to the administrative agency. Accordingly, such administrative rules have the effect of an external binding law order in combination with those of the administrative rules, unless they go beyond the limit delegated by the law in question.

(see, e.g., Supreme Court Decision 2006Du3742, Mar. 27, 2008). Furthermore, with respect to the interpretation of the laws relating to taxes or charges, the requirements for imposition or exemption is required or required to be mitigated.

It is not permitted to interpret a case in accordance with the law, and to expand or analogical interpretation without reasonable grounds, unless there are special circumstances.

(See Supreme Court Decision 2007Du9884 Decided October 26, 2007). B.

(1) Article 18(1)1 of the former Petroleum and Petroleum Substitute Fuel Business Act (amended by Act No. 8768 of Dec. 21, 2007 and enforced June 22, 2008; hereinafter “former Petroleum Business Act”) imports or exports petroleum to stabilize petroleum supply and demand and prices.