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The federal income tax statutes echos the language of the 16th amendment in praoclaiming that it reaches "all income from whatever source derived," (26 USC s. 61) including criminal enterprises; criminals who for you to report their income accurately have been successfully prosecuted for cibai. Since which of the amendment is clearly clearing away restrict the jurisdiction for the courts, is usually not immediately clear why the courts emphasize the language "all income" and forget about the derivation for the entire phrase to interpret this section - except to reach a desired political result.

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