The judgment of the court below is reversed.

A defendant shall be punished by imprisonment for one year.

However, for a period of two years from the date this judgment becomes final and conclusive.

1. Summary of grounds for appeal (unfair sentencing)

A. In light of all the circumstances, including the fact that the Defendant led to an offense and reflects, the circumstances to take into account the developments leading up to the issuance of a false tax invoice, the deposit of KRW 45 million to recover the damage inflicted on the embezzled victim, the Defendant was endeavoring to reach an agreement, and the Defendant did not have a criminal record of the same kind, the sentence imposed by the lower court (one year of imprisonment) is too unreasonable.

B. In light of the fact that in the case of violation of the Punishment of Tax Evaders Act by the prosecutor, the supply price of false tax invoices issued by the defendant is approximately KRW 1.7 billion, and the market price of the damaged vehicle is KRW 136 million, but the market price of the embezzled vehicle is KRW 1360 million, etc., the court below’s sentence (old: 2 years of imprisonment) is too unreasonable.

2. The crime of this case, as the representative director of the Co., Ltd. (hereinafter “Defendant Co., Ltd.”), issued three false tax invoices equivalent to KRW 1.71 billion in total of the supply value of tax invoices under the Value-Added Tax Act on three occasions, regardless of the fact that the Defendant, as the representative director of the Co., Ltd. (hereinafter “Defendant Co., Ltd.”), did not supply goods or services to F. In light of the fact that: (a) under a lease agreement on one of the passenger cars owned by the injured Co., Ltd.; (b) while concluding and using the lease agreement on one of the passenger cars owned by the injured Co., Ltd., it was delivered to the creditor I for the purpose of debt security; and (c) the issuance of false tax invoices is an act that disturbs the fair imposition and collection of taxes, and thus disturbs tax order by distorted the materials that form the basis for the calculation of value-added tax; and (d) the value of the vehicle embezzled by the Defendant is a large amount of KRW 1.36 billion in total,00 million in payment.