In March 2021, in U.S. v. Gentges, the court held that a taxpayer filing an erroneous tax return – despite his carelessness in reviewing it before he signed it – was nevertheless per se evidence of reckless conduct giving rise to the higher Willful FBAR penalties. Therefore, it was no defense that the taxpayer did not review his tax return carefully and was unaware of the incorrect answers to the foreign bank account questions on Schedule B. When a taxpayer signs his tax return, he is then charged with constructive knowledge of all items within that tax return.