Is Section 7207 a lesser included offence of a federal tax crime?

On the other hand, United States v. Bishop (1973) 412 U.S. 346, 93 S.Ct. 2008, 36 L.Ed.2d 941, indicates that 26 U.S.C. section 7207 is not a necessarily included lesser offense of a 7206(1) violation. The [155 Cal.App.3d 1156] opinion settled a difference among the circuits concerning how the word "willfully" should be interpreted as used in the various definitions of federal tax crimes. The court concluded it identified the same element in both section 7206(1) and 7207 violations (id. at pp. 359-360, 93 S.Ct. at 2016-2017), as well as in other violations. The taxpayer claimed he was entitled to a lesser included offense instruction as to 7207.

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