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The federal income tax statutes echos the language of the 16th amendment in proclaiming 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 cibai. Since the text of the amendment is clearly directed at restrict the jurisdiction within the courts, is actually also not immediately clear why the courts emphasize words "all income" and neglect the derivation of the entire phrase to interpret this section - except to reach a desired political end.
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