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Reasonable cause not to e-file

Our department will make "reasonable cause" determinations on a case-by-case basis, using our current "Reasonable Cause" standards (included in 20 NYCRR Sections 2392.1, 2396.11 & 2397.7).

We'll also take the following circumstances into account in determining whether reasonable cause exists:

  • Whether the preparer's New York State approved e-file software supports e-filing of a return
  • Whether the return was e-filed, but rejected for a condition that can't be identified or resolved
  • Whether there existed an extended internet outage at the preparer's place of business
  • Any other cause which appears to a person of ordinary prudence and intelligence as a reasonable cause for the failure to e-file and that clearly indicates an absence of willful intent to disobey the e-file mandate
  • A preparer's overall compliance with the New York State e-file mandate


While we'll make reasonable cause determinations on a case-by-case basis, the following facts and circumstances will never be considered reasonable cause:

  • A client's desire to opt out of e-filing
  • A preparer's failure to obtain an EFIN
  • Ignorance of the law
  • Reluctance to provide bank account information electronically
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