In some cases, a health-related move can qualify for an exclusion if the use was less than 2 years.  However, it is prorated based on the ACTUAL use during those two years.  Even if the circumstances were to qualify (which is questionable), it would be prorated.

So because there was zero use in 2 years, the taxpayer qualifies for 0/2 (0%) of the $250,000 exclusion.  So that is $0 of exclusion.

If the taxpayer had used it for 1 year in the last 2 years (the actual calculation uses days, not full years), then *IF* the health reason qualified, then the taxpayer would qualify for 1/2 (50%) of the $250,000 exclusion.  But because your client did not use it at all, there is no exclusion.