The defendant's appeal is dismissed.

1. The summary of the grounds for appeal (e.g., a fine of eight million won) of the original judgment is too unreasonable.

2. The following are the circumstances favorable to the Defendant: (a) the Defendant is against whom the judgment is made; (b) the actual profits of only KRW 4,781,00,000, which is about 20% of the refunded value-added tax; (c) the Defendant is paying the amount of additional tax through individual rehabilitation; and (d) the Defendant has no record of punishment except for the punishment of fines twice due to the crime

However, the crime of violating the Punishment of Tax Evaders Act not only causes serious harm to the national tax collection function, but also undermines the order of sound commercial transactions and causes harm to the general public to fulfill his/her duty to pay taxes in good faith, and there is a need to strictly punish the crime. There is no change in circumstances that can be considered as the reason for sentencing in the trial, and there is no other change in the circumstances that can be considered as the reason for sentencing in the trial, and in full view of all the sentencing conditions such as the defendant's age, character and behavior, environment, motive, means and consequence, etc.

3. As such, the defendant's appeal is without merit, and it is dismissed in accordance with Article 364 (4) of the Criminal Procedure Act. It is so decided as per Disposition.