There is a simple certification that no tax returns had to be filed within the last 4 years and no return exists. The document exists and just needs to be checked and signed. I have used it for clients in this situation. It has always kind of been my position that post-petition fees in a 7 were not paid from the Estate so the UST shouldn’t really care. My 2016 specifically states some of what isn’t covered and says that those things “will be billed at the attorney’s regular hourly rate of $X” Having said that I have the first case where I actually plan to charge a client for screwing around and causing me to have to attend a continued 341 (my retainer agreement specifically allows me to do so).