The IRS requires all tax prepares that file more than 100 returns a year to do so electronically. In 2012 the requirement covers any preparer that files 10 returns. However, there are no penalties if the preparer fails to do so. The GAO is recommending that the Tax Code be amended to allow the IRS to start issuing penalties. They currently can asses fines for failing to sign tax returns or provide their Prepaper Tax Identification Number.

One hurdle for tax preparers is that not all forms are available. Lets hope they continue to make all forms available for the electronic filer.