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Per the New York website, Who the tax preparer e-file mandate applies to:

If you can't electronically file the return because it's not supported by your approved e-file software or it can't be filed on our Web site, then you aren't required to e-file it.

Additional information for preparers is available on the New York State website:

More tax preparer e-file mandate information

E-file mandate penalties

Penalties for both Preparers and Individuals are outlined on the New York website E-file - mandate for business taxpayers:

Additional penalties for failure to e-file certain returns on or after January 1, 2012

If you or your preparer are required to file a tax document electronically and instead file on paper, you're subject to the following penalties: 
  • $50 penalty for each tax document not electronically filed
  • $50 penalty for failure to pay electronically
  • a penalty specific to your tax type for failure to file
In addition, any overpayment claimed on a return that was required to be electronically filed won't be eligible to receive interest until the document is filed electronically.

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