If an individual taxpayer has a "no tax due" return with a state department of revenue, then as a practical matter there generally is no actual penalty for not filing such a tax return. However, if you've already taken the trouble to complete your child's tax return for a given state, and figure the liability as being zero (no refund), then it's often a good idea just to file it anyway.
The main benefit in doing so is that this will eliminate the possibility of the state department of revenue later coming forward and questioning why no tax return was filed for Citizen X in a given tax year. To save the trouble and hassle of responding to an inquiry like that, it is often advisable to just file the state tax return in the first instance.
Such a state tax return can even be printed and mailed from TurboTax, rather than e-filed, so as to avoid any potential e-filing fee that may apply to the desktop software line of products. (I notice that your user ID indicates that you may be using Home & Business TurboTax desktop software, which is why this is mentioned here.)
However, the choice is the really up to the individual taxpayer. Often, simply for peace of mind, we would recommend filing a no-tax-due state return, where practical. That is what we respectfully recommend as a company, and what I as a CPA also recommend in private practice.
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