I encountered the same problem with MN eFile. It does not accept eFiled state tax returns if there is a late payment tax penalty applied to your return. You are directed to file by USPS mail. Unfortunately, TurboTax does not inform you of this during the eFile process sequence until you've already paid the state eFile fee via credit card. To obtain a refund of the fee, you have to call TurboTax customer support at [phone number removed].
To keep a late payment tax penalty from spoiling any future plans for state eFiling, use the quarterly (default) tax payment dates embedded in TurboTax, i.e., do not change them to reflect actual payment processing dates. TurboTax will assign no penalty and eFiling should work.
