According to Table 3 of Publication 501, if you he had net earnings from self-employment of $400 or more he is required to filed a tax return, whether he receives a 1099 or not. The key may be "Net" earnings. Did he have any expenses associated with earning the income? If so, those are subtracted to arrive at net income from self-employment.
The tables 1 and 2 describe the other situations when filing a return is required. If he is required to file for other reasons his net income from self-employment must be reported on his return even if below $400.
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