The IRS e-file system will not accept a return with $0 of Adjusted Gross Income. This restriction is imposed by the IRS systems, not TurboTax.
One way to work around this issue is to add $1 of interest income, which will give the return $1 of Adjusted Gross Income, but no tax due.
Most taxpayers with interest-bearing accounts will have at least $1 of interest each year to report, even if they did not receive documents to this effect. This is added in TurboTax under Wages & Income and then Interest and Dividends.
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