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.