Tax Return Preparers Must Use IRS e-File - Form 8944

Starting January 1, 2012, any tax return preparer who anticipates preparing and filing  11 or more Forms 1040, 1040A, 1040EZ and 1041 during a calendar year must use IRS e-File (unless the preparer or a particular return is administratively exempt from the e-File requirement or the return is filed by a preparer with an approved hardship waiver).
Members of firms must count returns in the aggregate. If the number of applicable income tax returns is 11 or more, then all members of the firm generally must e-File the returns they prepare and file. This is true even if a member expects to prepare and file fewer than 11 returns on an individual basis.
Specified tax return preparers may request an undue hardship waiver from the e-File requirement using Form 8944 - Preparer e-File Hardship Waiver Request. Form 8944 generally must be submitted to the IRS no later than February 15 of the year for which a waiver is being requested.