If he had no income, he does not need to file a return, unless he had one of the following situations:
- Had $400 or more in self-employment net earnings (gross income minus expenses)
- Had marketplace health insurance and you received advance payments for the premium tax credit
- He (or his spouse if filing jointly) received health savings account, Archer MSA, or Medicare Advantage MSA distribution
- He had wages of $108.28 or more from a church or qualified church-controlled organization that is exempt from employer social security and Medicare taxes
- He owes any special taxes, including any of the following:
- Alternative minimum tax
- Additional tax on a qualified plan, including an individual retirement arrangement (IRA), or other tax-favored account
- Household employment taxes
- Social Security and Medicare tax on tips you didn't report to your employer or on wages you received from an employer who didn't withhold these taxes
- Uncollected social security and Medicare or RRTA tax on tips you reported to your employer or on group-term life insurance and additional taxes on health savings accounts
- Recapture taxes
