But there's been (for about 10 years IIRC) a similar requirement for large partnerships in IRC 6011(e) paragraph 2, and that doesn't seem to have prevented e-filing in these cases. The applicable regulations seem to be Treasury Regulations, Subchapter F, Sec.
301.6011-3 which in paragraph d(1) define magnetic media as follows "Magnetic media. The term magnetic media means any magnetic media permitted under applicable regulations, revenue procedures, or publications. These generally include magnetic tape, tape cartridge, and diskette, as well as other media (such as electronic filing) specifically permitted under the applicable regulations, procedures, or publications." It's hard to imagine that the IRS will interpret this new amendment any differently.In light of this (together with what appears to heve been the congress's intent), I'd suspect that the courts (if asked) would read the refernce to magnetic media in paragraph 2 & (the new) paragraph 3 as shorthand for the "magnetic media or in other machine-readable form" of paragraph 1.
It seems to me that the intent here is to _significantly_ broaden the IRS's ability to require non-papaer returns. [previously, the secretary couldn't ever require them for returns for individuals, estates or trusts. Nor was he allowed to require anyone filing fewer than 250 returns per year to file on magnetic media].
Will.