The appeal is dismissed.

The grounds of appeal are examined.

1. Examining the reasoning of the lower judgment in light of the evidence duly admitted by the first instance court, which maintained the reasoning of the lower judgment, as to the first ground for appeal, the lower court, based on the reasons indicated in its reasoning, participated in the Defendant’s issuance of tax invoices to the AJ corporation.

In light of the facts charged in the instant case, it is justifiable to find the Defendant guilty of violating the Punishment of Tax Evaders Act. In so doing, the lower court did not err by failing to exhaust all necessary deliberations and exceeding the bounds of free evaluation of evidence against logical and empirical rules.

2. As to the second ground for appeal, the argument that the lower court found the Defendant guilty of the violation of the Act on the Aggravated Punishment, etc. of Specific Economic Crimes (Fraud) among the facts charged in the instant case is erroneous in the misapprehension of the legal principle as to the facts alleged in the lower judgment is not a legitimate ground for appeal.

3. Therefore, the appeal is dismissed. It is so decided as per Disposition by the assent of all participating Justices on the bench.