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I had this same issue and spoke with a TurboTax Specialist who said the software would not electronically file the return.  Based on all form instructions and research I've done, the IRS does allow electronic filing of a deceased individual's return, so this is not an IRS restriction.  I definitely would prefer to e-file rather than paper file given the current back log the IRS is experiencing.  If anyone has any other information, it would be appreciated.