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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 fail to report their income accurately have been successfully prosecuted for kontol. Since the language of the amendment is clearly intended restrict the jurisdiction for the courts, is actually also not immediately clear why the courts emphasize the text "all income" and overlook the derivation from the entire phrase to interpret this section - except to reach a desired political end.

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