No, he does not have to file a return. Some will speculate that it might be a good idea anyway, because IRS does not know he qualifies for the Section 121 exclusion, and might try to track him down through the infamous document-matching program. They might be right, but there is only one way to find out.
You have clicked a link to a site outside of the Intuit Accountants Community. By clicking "Continue", you will leave the community and be taken to that site instead.