26, U.S.C., 7207, makes it a Federal crime or offense for anyone to willfully file a Federal income tax return knowing it to be false in some material way.
A person can be found guilty of that offense only if all of the following facts are proved beyond a reasonable doubt:
First: That the person filed an income tax return which was false in a material way as charged in the indictment; and
Second: That the person did so knowingly and willfully, as charged.
It is not necessary that the Government be deprived of any tax by reason of the filing of the return, or that it even be shown that additional tax is due to the Government, only that the person willfully filed a false return.