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In United States v. Snider, 502 F.2d 645 (4th Cir. 1974), a Quaker had filed a W-4 form in which he claimed three billion dependents. He attached a letter addressed to the Internal Revenue Service explaining that he felt a sense of responsibility for all of the people of the earth and a strong religious opposition to war. He decried this country's participation in the war in Southeast Asia and stated that he would not willingly pay federal income taxes as long as this country was engaged in that war. A divided panel of the court felt that no criminal sanctions should be imposed upon him, for there was no deceptiveness in the form as filed; it simply should have been treated by the employer as one claiming no dependents.

The holding in Snider has been criticized. Other courts have held that a false return is false within the meaning of the statute whether or not it is deceptive. United States v. Hudler, 605 F.2d 488, 490 (10th Cir. 1979), cert. denied, 445 U.S. 961, 100 S. Ct. 1647, 64 L. Ed. 2d 236 (1980); United States v. Buttorff, 572 F.2d 619, 626 (8th ...

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