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I have three (3) accepted returns (mine, a granddaughter and a grandson) and two (2) rejected returns (daughter and a grandson).  TurboTax told me I was at five (5) when I tried to efile my sons return.  Apparently, rejected returns DO count towards the limit of five.  I haven't started to address the $50 in state filing fees for the two rejected state returns.  Problem seems to be that daughter's son's SSN was used by someone who filed their return already - either a fraudulent filing to scam IRS or an innocent typo by someone.