All appeals by the Defendants are dismissed.

1. Summary of grounds for appeal;

A. Legal doctrine 1) The violation of the Punishment of Tax Evaders Act due to the submission of a list of total tax invoices by false sales sources (crime 1-A in the judgment below) (hereinafter “Defendant Company”) Defendant A Co., Ltd. (hereinafter “Defendant Company”) succeeded to the construction work of the Franchis Construction Corporation (hereinafter “instant construction work”) from the former contractor in the middle of the construction business at Namyang-si, Namyang-si, which was ordered by the company Barun (hereinafter “ Barun”) to the former contractor, and succeeded to all matters related to the said construction work, such as construction cost, wages to the subcontractor, etc. of the former constructor. In fact, the remainder of the construction work was verified. After confirming that the former constructor did not have any tax invoice issued, the former constructor prepared a list of total tax invoices by adding up the parts constructed by the former constructor to the tax office.

Therefore, the Defendants cannot be deemed to have submitted a false list of total tax invoices by entering them in a false manner.

B) On December 29, 2012, a contractor created a sales contract for three bonds (which are equivalent to KRW 59,166,680 per bonds) among the buildings newly constructed as part of the instant construction (hereinafter “the instant building”) in lieu of the construction cost to the Defendant Company on December 29, 2012. The Defendant Company entered a false list of accounts for each of the above buildings on the sales basis, since it was not completed the registration of transfer of ownership due to the exercise of lien by other creditors.

could not be seen, or there was an intentional act against the Defendants.

shall not be deemed to exist.

2) As to the violation of the Punishment of Tax Evaders Act due to the submission of a list of the separate tax invoices by a false purchaser (criminal facts No. 1-B in the judgment below), Defendant Company succeeds to the instant construction from the former construction business entity, such as the above-mentioned No. 1-A, and succeeds to all the construction costs, etc. for the former subcontractor, the former constructor Company C (hereinafter “C”).