Per IRS guidelines, starting January 1, 2012, any tax return preparer who anticipates preparing and filing 11 or more Forms 1040, 1040A, 1040EZ and 1041 during a calendar year must use IRS e-file (unless the preparer or a particular return is administratively exempt from the e-file requirement or the return is filed by a preparer with an approved hardship waiver).

Given the phrasing of the question, that return is likely administratively exempt, assuming the proper form is submitted). The client would have to sign the form.