The defendant's appeal is dismissed.

1. Summary of grounds for appeal;

A. misunderstanding of facts1) After establishing the F, the Defendant: (a) purchased and sold goods, such as waste Dongs, from the “C head” and “D head”; and (b) discontinued F without paying value-added tax on the wind that rapidly aggravated financial standing. Therefore, there was no fact that the Defendant, in collusion with the above C head and D head, intended to evade value-added tax by fraud or other unlawful act; (b) the Defendant actually supplied goods, such as waste Dongs, and actually submitted a tax invoice by sales place; and (c) there was no fact that the Defendant submitted a false entry of the tax invoice by sales place.

3) Nevertheless, the lower court found all of the facts charged in this case guilty, which affected the conclusion of the judgment by misunderstanding the facts, and thereby adversely affecting the conclusion of the judgment. (B) The lower court’s sentence of imprisonment with prison labor and fines of KRW 4.2 billion imposed on the Defendant is too unreasonable.

2. Determination

A. 1) On the assertion of mistake of facts, the court below held that, in full view of the circumstances established by the evidence adopted by the court below, the defendant established the "C chief" and the "D chief" in collusion with the "C chief" and "D chief" to evade value-added tax in the same manner as indicated in the judgment of the court below, and subsequently closed down a large amount of transactions. As such, the actual supplier of H et al. was not the F but the C chief and D chief, and the party who actually supplied H et al. was the party who actually supplied it, the court below determined that the defendant could sufficiently recognize the fact that the defendant submitted to the tax office the list of total tax invoices by the selling location, which was falsely recorded as if the F actually supplied it. 2) The court below and the court below duly adopted and investigated by the evidence of the court below, the above decision of the court below is correct, and the defendant is also justified