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If your mother had no taxable income in 2023 she has no reason to file a tax return unless she has a 1095A for marketplace health insurance.
Who has to file?
http://www.irs.gov/uac/Do-I-Need-to-File-a-Tax-Return%3F
There is no such thing as compliance to file a tax return.
If she did not receive any income of any kind in 2023 then there is no reason or need to file a 2023 tax return.
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