So, if all the distributions were used for qualified expenses AND THERE IS NO OTHER INCOME, he does not need to file a separate tax return.
even if there is other income, as long as it's earned income and below $12,000, and there were no withholdings, then he does not need to file a separate tax return.
if he did work and there were withholdings. the only way to get the withholdings back back is to file.
