"Any Act or Endeavor" Test
To attempt to do an act does not imply a completion of the act, or in fact any definite progress toward it. Any effort or endeavor to effect the act will satisfy the terms of the law.
United States v. Robles, 185 F. Supp. 82, 85 (N.D. Cal., 1960). This position must be examined with an eye to those cases which have striven to distinguish the terms "attempt" and "endeavor," thereby forcing a definition of the former term in much the same terms as under the dangerous proximity test. See Osborn v. United States, 385 U.S. 323, 333 (1966). The gravity of the violations encompassed by the statute would indicate the propriety of prosecution as an attempt for conduct which might as to other violations be considered mere preparation or endeavor.
[cited in USAM 9-65.700]
Updated February 19, 2015