The judgment of the court below is reversed.

Defendant shall be punished by a fine of 12,000,000 won.

The above fine shall not be paid by the defendant.

1. The summary of the grounds for appeal (e.g., a fine of KRW 18 million) is too unreasonable.

2. The meaning of the language and text of Article 20 of the Punishment of Tax Evaders Act provides that "no restriction on the concurrence of fines under Articles 3 through 6, 10, and 12 through 14 of the Punishment of Tax Evaders Act shall apply to any person who commits an offense," and the meaning of Article 38 (1) 2 of the Criminal Act provides that where several of the above offenses for which judgment has not become final and conclusive are punished as a fine at the same time, the method of imposing a fine shall not apply to the case where a person is punished as a fine at the same time." As such, the main text of Article 38 (1) 2 of the Criminal Act provides that "an aggravated sentence shall be imposed within the limit of 1/2 of the maximum amount of fine for the serious offense" as provided for in the main sentence of Article 38 (1) 2 of the Criminal Act, where a fine is imposed

In addition, it is reasonable to interpret that the same applies to the violation of the Punishment of Tax Evaders Act due to the violation of Articles 3 through 6, 10, and 12 through 14 of the Punishment of Tax Evaders Act and the violation of the Punishment of Tax Evaders Act due to the violation of Article 11 of the Punishment of Tax Evaders Act, which does not apply Article 20 of the same Act, when the violation of the former part of Article 37 of the same Act amounts to concurrent crimes as prescribed in the former part of Article 37 of the same Act (see Supreme Court Decisions 2006Do8435, Apr. 13, 2007; 2010Do18154, Apr. 28, 2011). However, the lower court, without separately prescribing a fine for the violation of the Punishment of Tax Evaders Act due to the issuance of false tax invoices, together with the violation of the Punishment of Tax Evaders Act by using another person’s name due to the evasion of taxes or compulsory execution selected, as well as the former part of Article 37 of the Criminal Act.