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I was just on the phone with TT for 1-1/2 hours re this issue.  I prepared my 5th return (for my daughter), and it got rejected for e-filing because of incorrect AGI.  She filed late last year and probably the IRS had not processed her return by December 10.  When I tried to re e-file with a 0 AGI (as shown in the instructions), her return was rejected again because I was over the 5 limit.  I was told by the TT representative that every time I try to e-file, that counts as one even if it was the same return.