ANY PERSON WHO WILLFULLY ATTEMPTS IN ANY MANNER TO EVADE OR DEFEAT ANY TAX IMPOSED BY THIS TITLE OR THE PAYMENT THEREOF SHALL, IN ADDITION TO OTHER PENALTIES PROVIDED BY LAW, BE GUILTY OF A FELONY AND, UPON CONVICTION THEREOF, SHALL BE FINED NOT MORE THAN $100,000 ($500,000 IN THE CASE OF A CORPORATION), OR IMPRISONED; 26 U.S. CODE § 7201
