The defendant's appeal is dismissed.

1. The summary of the grounds for appeal in the judgment of the court below (the fine of 60 million won) is too unreasonable.

2. We examine the judgment. Although the defendant paid KRW 42,30,050 out of KRW 226,639,80 of the corrected tax amount of KRW 226,639,80 (the corrected tax amount of KRW 77,253,290), the court below appears to have reduced the amount of fine under the summary order by reflecting such circumstances, and there is no change in circumstances to be different from the punishment of the court below at the time of the trial, and all matters concerning the sentencing specified in the records and arguments of this case are considered to be appropriate, the defendant's assertion is without merit.

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