The judgment below

The fourth part of the judgment is reversed.

A fine of KRW 10 million shall be imposed on the 4th offense in which the defendant's decision was made.

1. Summary of grounds for appeal;

A. misunderstanding of facts and misunderstanding of legal principles: The fourth crime in the holding of the court below is a crime committed prior to the violation of the Punishment of Tax Evaders Act, which became final and conclusive on June 2, 2012.

B. The lower court’s sentence of unreasonable sentencing is too unreasonable.

2. Determination

A. Comprehensively taking account of the evidence duly adopted and examined by the lower court, the same year as from January 1, 2012 by the Defendant, based on erroneous facts and misapprehension of legal doctrine.

6. Between July 21, 201, a tax invoice was issued in the form of the supply of goods or services equivalent to KRW 100,300,000,000 in total among three copies of the tax invoices by Oralenna Co., Ltd., and thereafter, a tax accountant requested by the Defendant submitted a false list of the total tax invoices to the Government on July 25, 2012. Thus, the “act of submitting a false list of the total tax invoices to the Government” under Article 10(3)3 of the Punishment of Tax Evaders Act was submitted on July 25, 2012. Thus, this part of the Defendant’s assertion is without merit.

B. In full view of all the sentencing conditions indicated in the records and arguments of the instant case of unfair sentencing, the lower court’s punishment of the first or third crimes as to the judgment is too heavy, but the lower court’s punishment of the fourth crime of the judgment is too unreasonable.

3. According to the conclusion of the judgment of the court below, the defendant's appeal as to the part concerning the crime Nos. 1 through 3 of the judgment of the court below is dismissed pursuant to Article 364 (4) of the Criminal Procedure Act, and since the defendant's appeal as to the part concerning the crime No. 4 of the judgment of the court below is justified, this part is reversed pursuant to

Criminal facts

The summary of the evidence and the criminal facts of the defendant recognized by this court and the summary of the evidence are as stated in the corresponding column of the crime No. 4 of the judgment of the court below. Thus, it shall be quoted under Article 369 of the Criminal Procedure Act.

Application of Statutes

1. Criminal facts;