This has been a common issue for preparers that didnt read the rules. 

As mentioned above, you can't defer the SE taxes if they have already been paid, showing a refund on the return means they were already paid.

Would have been nice for ProSeries to flag (or even disallow) this situation, or maybe it did flag it in the Diagnostics?   I didn't have any clients that were interested in deferring, so I didnt see this when running through Review.