A customer was able to clear this error using TurboTax Desktop version by doing the following:
1. Switch to Forms Mode.
2. Find CA Form 565 K-1 Partnership Worksheet.
3. Note Line 7 of the form. Does it say "Untitled". If so, go to Step 4. If not, no answer.
4. Find and select the untitled Schedule E Worksheet in the list of forms in the return.
5. Delete the empty, untitled Schedule E Worksheet.
6. Return to Step-by-Step Mode and run SmartCheck again.
Error message should be cleared.
There's currently another open question on this as it also happened to me. I believe it's currently a bug in TurboTax. If you're lucky, it's that your K-1 needs to be a Trust which "does" have Line 4c included. But seems to be a bug when TurboTax decides to move data from a Partnership/LLC-type K-1 to a new worksheet. Hopefully they'll have a bug-fix update soon...