The taxpayer, otherwise required to e-file, has filed a petition with the bankruptcy court under Chapter 7 of the Bankruptcy Act.

The taxpayer will need to follow Notice 2010-13 to request a waiver.  In the subject line or body of the waiver request indicate that this is a Waiver Under Chapter 7 of the Bankruptcy Code and provide all the applicable information including a copy of the Bankruptcy Petition and the information appointing the U.S. or case trustee.