TheTaxBook has a four page update on how tax preparers can opt out of this new stupid requirement to e-file client tax returns. 

Form 8944 is the IRS request to be exempted from this requirement. 

Reading the form and its instructions, I am drawn to this section which defines the issue of filing tax returns. 

From Tax Info

I guess there are tax prep firms that actually send in the paper 1040s directly to IRS.  It has always been our policy to prepare the tax returns and give them to the clients to sign and mail to IRS.  Only on a very few occasions, such as when a client is very ill or out of the country, have we actually mailed client tax returns from our office to the IRS.

Under this definition of having to file more than 100 tax returns (10 next year) rather than prepare that many, I don’t feel that we are even subject to this new rule; so I see no need to submit a 8944. 

Other preparers who want to avoid the e-filing requirement may want to consider allowing their clients to also mail in their own 1040s.