What are the elements of 26 U.S.C. C. 7206(1) of the Criminal Code and what is the test for a perjury charge?

1 The elements of 26 U.S.C. 7206(1) are: (1) the defendant made and subscribed a return, statement, or other document that was incorrect as to a material matter; (2) the return, statement, or other document contained a written declaration that it was made under penalty of perjury; (3) the defendant did not believe the return, statement, or other document to be correct as to every material matter; and (4) the defendant acted willfully, with the specific intent to violate the law. United States v. Marabelles, 724 F.2d 1374, 1380 (9th Cir.1984).