The defendant's appeal is dismissed.

1. The abstract of the grounds for appeal by the defendant shall be considered to the extent of supplement in case of supplemental appellate briefs not timely filed by his defense counsel;

A. The Defendant did not refuse to comply with E’s request due to an individual relationship with E, and issued and received false tax invoices or submitted a list of total tax invoices by the purchaser and seller, and thus did not obtain any economic benefits therefrom. Therefore, the Defendant did not have a profit-making purpose.

Nevertheless, the lower court found the Defendant guilty of the facts charged on the premise that the Defendant had profit-making purposes, and erred by misapprehending the legal doctrine on the purpose of profit-making in violation of the Act on the Aggravated Punishment, etc. of Specific Crimes.

B. The sentence imposed by the lower court (two years of suspended execution in August, and fine of 390,000,000 won) is too unreasonable.

2. Determination

A. Determination on the assertion of mistake of facts and misapprehension of legal principles is not limited to the purpose of widely acquiring economic benefits; “for profit” under Article 8-2(1) of the Act on the Aggravated Punishment, etc. of Specific Crimes; “for the purpose of obtaining direct economic benefits by itself” or “for the purpose of obtaining or receiving value-added tax unfairly by using a tax invoice received or received”; and “for the purpose of obtaining economic benefits directly acquired as a result of using a tax invoice received or received” (see, e.g., Supreme Court Decision 2011Do9592, Oct. 27, 2011). 2) Specific judgment of the lower court and the trial by the trial court are duly adopted and the following facts and circumstances recognized by the evidence are examined by the evidence. In light of the aforementioned legal principles, the Defendant’s profit-making.