The change in unemployment law certainly helped him. The best way to answer is that if there is $0 in tax, he technically does not need to file. However, if he is entitled to a refund he will certainly want to file to get that money back. And given the situation with the unemployment exclusion, it might not be a bad idea to go ahead and file anyways and eliminate any possibility of confusion by the IRS or Maryland.
So for this year I would recommend he file even if not technically required to do so.
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