The judgment of the court below is reversed.

Defendants shall be punished by a fine of three million won.

The above fines are imposed by the Defendants.

1. Summary of grounds for appeal;

A. In this case, the prosecution of this case is unlawful inasmuch as the prosecution of this case was instituted on the grounds of accusation by the director of the Goyang Tax Office and the director of the Central District Tax Office having no jurisdiction despite the fact that only the director of the Central Tax Office and the director of the Central Tax Office, who is the competent government office, may

B. The sentence of the lower judgment on the Defendants on the grounds of unreasonable sentencing (a fine of five million won) is too unreasonable.

2. Determination

A. Article 6 of the former Punishment of Tax Evaders Act (amended by Act No. 9919, Jan. 1, 2010) provides that "an accusation against any offense under this Act shall be raised by the Commissioner of the National Tax Service, the commissioner of a regional tax office, the head of a regional tax office, or a public official engaged in taxation." Article 21 of the Punishment of Tax Evaders Act provides that "no public prosecutor shall institute a prosecution against any offense under this Act unless the accusation is filed by the Commissioner of the National Tax Service, the commissioner of a regional tax office, or the head of a tax office." Article 21 of the Punishment of Tax Evaders Act provides that "no public prosecutor shall institute a prosecution against any offense under this Act" as a person who has the right to file a complaint and does not limit the same to "the Commissioner of a regional

Therefore, even if the Seoul Regional Tax Office is not a competent authority as argued by the Defendants, the indictment cannot be deemed unlawful on the grounds that it filed a complaint with the director of a regional tax office who is not the director of the regional tax office. Ultimately, the Defendants’ assertion of legal principles

B. The Defendants presented a tax payment certificate stating that the Defendants, who made a judgment on the assertion of unfair sentencing, recognized the instant crime and expressed the form of reflecting it, and that the Defendants paid in full the pertinent taxes, including the instant tax, in the trial.