Help with Lifetime Learning Credit

I'm filing for my son.  He is 26 years old and attending Medical School (second year).  I added his 1098-t and his income was about 36k for the year, including $3k for earned income and $33k for investment (unearned).   Yet he is "ineligible" for the LLC.  He now owes according to TT $270 in federal and $1600 in MA State Taxes - Shouldn't he be eligible for LLC since he spend $69k in tuition charges on 1099T?