Madoff falsified statements from his own firm. It's not like the statements came from a reputable firm like Scottrade etc. We are overthinking this. The posers will always find a 1001 reasons why it can't be done (just like they have a 1001 reasons why they can't show their actual trading statements) because then they would be exposed for the Pretenders they are. I guess if somebody provided their 1040s they do would be deemed falsified. You don't mess with the IRS and sending out false 1040s as documentation.