ress has increased the po tential penalty to not more than 8100,000. Tax Equity and Fiscal Responsibility Act of 1982, Pub.L No. 97-248, § 329, 96 Stat 324, 617-18 (1982). 2. Title 26 US.C. § 7206(1) provides in pan: Any person who— (1) DECLARATION UNDER PENALTIES OF PERIURY.—Willfully makes and sub-