The judgment below

The guilty portion against the Defendants is reversed.

Of the facts charged in this case against the Defendants.

1. Of the instant facts charged, the lower court found not guilty of the charge of evading each value-added tax related to C, the Dispute Resolution D, the Dispute Resolution E, the Resolution Fund, the Resolution Fund, the Resolution Fund, and the Resolution Fund and the Resolution Fund, and the issuance of each false tax invoice related to the Resolution Fund I, J Co., Ltd., and the Resolution Fund K, and only the Defendants appealed against the guilty portion of the judgment below.

Therefore, the part of the judgment of the court below is separated and confirmed as it is, and excluded from the scope of the judgment of the court, and only the guilty part is subject to the judgment of this

2. Summary of grounds for appeal;

A. Inasmuch as Defendant A was aware that the Dispute Resolution Co., Ltd., the Dispute Resolution Co., Ltd., the Dispute Resolution Co., Ltd., the Dispute Resolution Co., Ltd., and the Dispute Resolution Co., Ltd., were the actual transaction parties, Defendant A was provided with closed cables, etc. (hereinafter referred to as “instant transaction” through a transaction with the said companies”) with the aforementioned companies, unless it is proven that there is any circumstance such as that Defendant A conspired with the said companies to consume value-added tax or received a refund after the said companies, Defendant A may not be punished

Furthermore, since the subject who evaded the value-added tax in this case is the management company, the LASN, the LAS, and the LAS, the Defendants cannot be the subject of the violation of the Punishment of Tax Evaders Act concerning the exclusion of value-added tax in this case

Although the Defendants were misunderstanding the legal principle that punishing the Defendants by applying Article 10(3) of the Punishment of Tax Evaders Act would violate the principle of prohibition of analogical interpretation of penal provisions, the charges belonging to the scope of the judgment of the court are related to Article 3(1) of the Punishment of Tax Evaders Act, and such misunderstanding of

(B) The defendant's assertion that it was not revealed that there was a conspiracy with the bomban enterprise or the signboard company, or that there was an accomplice, overlaps with the assertion of mistake of facts, and thus, I will examine the decision of mistake of facts within the scope

Even if the Defendants are convicted of unfair sentencing, it shall be accepted.