All appeals by the Defendants are dismissed.

1. The summary of the grounds for appeal is too unreasonable that each sentence (for defendant A: 2 years of suspended sentence of imprisonment with prison labor for 6 months; for defendant B: fine of 10 million won) declared by the court below to the defendants is too unreasonable.

2. The circumstances favorable to the Defendants are as follows: (a) the Defendants appeared to reflect each of the instant crimes; (b) the full payment of the evaded tax amount; (c) Defendant A did not have any record of punishment for the same crime; and (d) there was no record of punishment exceeding the fine.

However, each of the crimes of this case is an offense causing serious harm to the appropriateness and fairness of the national tax administration, and there is a need to strictly punish it. The value-added tax and corporate tax evaded by Defendant A reaches KRW 380 million in total, and the total value indicated in the tax invoice not issued by Defendant A is a large amount of KRW 4 billion, and other unfavorable circumstances, such as the Defendant A’s age, character and conduct, circumstances leading to the crime, means and consequence of the crime, and all of the sentencing conditions indicated in the records and arguments of this case, such as the circumstances after the crime, are considered as inappropriate.

Therefore, the above assertion by the Defendants is without merit.

3. As such, the Defendants’ appeal is without merit. Thus, all of the appeals are dismissed under Article 364(4) of the Criminal Procedure Act. It is so decided as per Disposition.

However, in accordance with Article 25(1) of the Regulation on Criminal Procedure, Article 3(1) of the Punishment of Tax Evaders Act in the part of “Article 3(1) of the Punishment of Tax Offenses Act” in the part of “Article 3(1) of the Punishment of Tax Offenses Act” shall be respectively dismissed, and Article 20 of the Punishment of Tax Offenses Act in the part of “1. Selection of the Punishment of Tax Offenses Act” shall be deleted, and Article 20 of the Punishment of Tax Offenses Act in the part of “1. Concurrent Crimes” shall be construed as “Article 37 of the Criminal Act and Article 20 of the Punishment of Tax Offenses Act” shall be construed as “Article