Not exactly run into this - shouldn't be a problem. Get a letter from the homeowner stating that he doesn't need to file tax returns and has no tax return for 2012, 2011. I find more facts included can be helpful. Possibly, they will demand it to be notarized - that doesn't make sense, but they do things like that. The "specialist" has to CYA and that is what the letter does.
We'll probably need a variance from HUD too...
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