Right now I have my Evidence book on the table. The current chapter deals with exceptions to hearsay that require unavailability of the witness. The Federal Rule that covers this is 804.
The exciting part comes from Williamson v. United States here on Page 204:
To decide whether Harris' congession is made admissible by Rule 804(b)(3), we must first determine what the Rule means by "statement," which Federal Rule of Evidence 801(a)(1) defines as "an oral or written assertion."
Scintillating, isn't it? It's still better than the Tax Code that defines "Income" as any income from any source. i.e. Income means income.
On a completely unrelated note, I think I'll head to Jack in the Box for dinner tonight.