The defendant's appeal is dismissed.

1. The summary of the grounds for appeal is too unreasonable that the sentence imposed by the court below on the defendant (two years and six months of imprisonment and fine of 3.1 billion won) is too unreasonable.

2. Each of the instant crimes committed by the Defendant, while substantially operating multiple petroleum wholesalers, was issued a false tax invoice even though the Defendant did not actually receive oil on the ground of the nominal branch, and did not issue or not issue a false tax invoice despite being supplied or supplied, and the value-added tax and comprehensive income tax were evaded by receiving false tax invoices and filing a false tax invoice by omitting sales, and thus, the crime and method of crime are very poor; the supply value of the tax invoice issued by the Defendant is 12.1 billion won in total; the supply value of the tax invoice issued by the Defendant is 12.1 billion won in total; the amount of tax evaded is 2.1 billion won in total; and the amount of tax evaded is 2.1 billion won in total; each of the instant crimes committed by the Defendant requires to punish the sound order of commercial transactions by encouraging non-data transactions and seriously obstruct the State’s legitimate exercise of tax collection authority; and some of the instant crimes committed by the Defendant without being subject to the judgment of the lower court that was committed by the Defendant during the crime of violating the Punishment of Tax Evaders Act.

On the other hand, each of the crimes in this case is against the defendant's intention to commit each of the crimes in this case, and the fact that each of the crimes in this case is concurrent crimes between the crime of violating the Punishment of Tax Evaders Act and the crime of violating the latter part of Article 37 of the Criminal Act in the judgment of the court below

The above circumstances and other arguments, including the defendant's age, character and conduct, environment, motive, means and result of the crime, and the circumstances after the crime.