I have that one!

1) Get your return all done and ready to file.

2) Copy the Lacerte file. Now you have two for the same client. Re-REP (no charge) if needed.

3) Print the 3800 to PDF. 

4) In one file, delete the passive activity credit inputs. Verify that the return is otherwise still correct. Attach the PDF 3800 to the e-file screen. E-file from this file.

5) Proforma the other file.

6) Repeat every single year until at least a dollar of credit frees up.

No problems e-filing, and no IRS correspondence (although with those returns, good luck getting any matching system to work) for multiple years running.