Thanks! I do understand that the state tax requirements may be different, I'm just asking about the federal portion. The first requirement is clarified in the following paragraph on IRS web site:
"You had no tax liability for the prior year if your total tax was zero or you didn’t have to file an income tax return."
He did not have to file an income tax return for the prior year since he had no income, so I'm not sure why it's not satisfied...
