The defendant's appeal is dismissed.

1. The summary of the grounds for appeal (a fine of KRW 15 million) pronounced by the lower court is too unreasonable.

2. The judgment of the court below was made on November 23, 2011 that the Defendant committed the crime of this case, which led to the confession of all of the crime of this case and there was no record of criminal punishment for the same crime before the crime of this case was committed, and on November 23, 2011, the above judgment became final and conclusive. The crime of this case is in the concurrent relationship between the crime of violation of the Punishment of Tax Evaders Act and the latter part of Article 37 of the Criminal Act, and the punishment should be determined at the same time under Article 39(1) of the Criminal Act, taking into consideration the equity between the case of the crime of this case and the case of concurrent relationship between the crime of violation of the Punishment of Tax Evaders Act and the latter part of Article 37 of the Criminal Act. However, the crime of this case is a case where the Defendant was issued a false tax invoice at least 36 times in total for eight months in order to get the refund of value-added tax, and the punishment of the Defendant is unreasonable in light of the law of crime and period, total tax invoices, total amount of the Defendant’s tax order, and extenuating circumstances.

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

However, the judgment of the court below ex officio under Article 25 (1) of the Regulation on Criminal Procedure.