district court against any individual who knowingly falsifies or who knowingly fails to submit or disclose any information that such individual is required to submit or disclose pursuant to this section or section 6103(l)(23) of the Internal Revenue Code of 1986. The court may assess against such individual a civil penalty in an amount of not more than $50,000. (2) It shall be unlawful for any person to knowingly— (A) falsify any information that such person is required to submit or disclose under this section or section 6103(l)(23) of the Internal Revenue Code of 1986