First, one attempts to commit tax evasion when he files a false return. One of the leading cases in California making this point is United States v. Boulware , 384 F.3d 794 (2004), 470 F.3d 931, 934 (9th Cir. 2006). Second, one attempts to commit tax evasion when he files a false amended return. A lead case in California on this point is Norwitt v. United States , 195 F.2d 127, 133-34 (9th Cir. 1952), cert. denied , 344 U.S. 817 (1952). Third, one attempts to commit tax evasion when (1) he fails to file a return and (2) his action is coupled with an “affirmative act of evasion,” like making an affirmative act to conceal or mislead the government. The name for this third kind of evasion is “Spies evasion” after the case bearing that name. Spies v. United States , 317 U.S. 492, 498-99 (1943). The nature of the “affirmative action” here is, in turn, satisfied by many possible actions (See Q&A on “Spies evasion” doctrine).