I have never looked up the e-filing requirements for the 5227 until today.  I have seen a handful of posts about the requirement  but never took the time to look at the instructions until now.  I assumed that the requirement was kinda like the 990 requirements where you had no choice, it had to be e-filed.  However, after looking at the instructions, I see that you are required to e-file the form if you file at least 10 returns.  That requirement is the same requirement as the 1040 filing but you can opt out if you file the handy dandy election that gives you a few excuses, including "the client wants to file a paper return."  The 5227 instructions provides a paragraph for waivers and exemptions including undue hardships.  My client is going to have an undue hardship financially if I have to pay Intuit extra to use one of their other two softwares plus learn how to use it.