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The federal income tax statutes echos the language of the 16th amendment in on the grounds that it reaches "all income from whatever source derived," (26 USC s. 61) including criminal enterprises; criminals who neglect to report their income accurately have been successfully prosecuted for cibai. Since the text of the amendment is clearly meant to restrict the jurisdiction among the courts, it really is not immediately clear why the courts emphasize the word what "all income" and overlook the derivation of the entire phrase to interpret this section - except to reach a desired political conclusion result.

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