All appeals are dismissed.

The grounds of appeal are examined.

The facts constituting a crime have to be proved to the extent that there is no reasonable doubt (Article 307(2) of the Criminal Procedure Act). However, the selection of evidence and the probative value of evidence conducted on the premise of fact-finding belong to the free judgment of the fact-finding court (Article 308 of the Criminal Procedure Act). For the reasons indicated in its reasoning, the lower court determined that Defendant C constitutes a person who actually supplied goods to Defendant C and is obligated to prepare and issue tax invoices; the Defendants recognized that Defendant C is not the party who actually supplied the original unit, but the Defendant Company was the Defendant Company B, and thus, did not accept the Defendant’s allegation of the grounds for appeal as to the mistake of facts and misapprehension of legal principles.

The allegation in the grounds of appeal is the purport of disputing the determination of the lower court on the facts that led to such determination. It is nothing more than denying the lower court’s determination on the selection and probative value of evidence, which belongs to the free judgment of the fact-finding court. In addition, even after examining the reasoning of the lower judgment in light of the aforementioned legal principles, the relevant legal principles as indicated in the lower judgment, and the evidence duly admitted, the lower court did not err by misapprehending the legal doctrine on the interpretation and application of Article 10(1)1 of the Punishment of Tax Evaders Act, applying the principle of substantial taxation, and failing to exhaust all necessary deliberations, or by exceeding the bounds of the principle of free evaluation in violation of logical

The Supreme Court precedents cited on the grounds of appeal are different from the instant case, and thus are inappropriate to be invoked in the instant case.

Therefore, all appeals are dismissed. It is so decided as per Disposition by the assent of all participating Justices on the bench.