IND-044-01 e-file error
If checkbox 'PowerOfAttorneySignedByInd' is checked in the return, then 'PrimaryDeathDt' must not have a value. (rule IND-044-01).
Solution
If you're filing Form 2848, Power of Attorney, and the taxpayer is deceased, you'll need to file the return on paper with Form 8948, according to IRS e-file specifications.