1041 -- file or no?

Client formed an irrevocable trust during 2022. We weren't expecting any income, however the client has conveyed that they received a 1099 from the brokerage that reports $15 of interest (not de minimis, so it's going to the IRS).

Based on the 1041 instructions, we should file. Normally, we'd get a $100 exemption for a complex trust, and that would translate to no tax due with this fact pattern. Client doesn't really want to file, and I don't blame them.

Would the IRS send a notice for tax, P&I on the $15 if the client chose not to file? Are there any other ramifications beyond a statute of limitations that does not close?

With the $100 exemption there would be zero taxable income, and since gross income is less than $600, there is no requirement to file.

Who Must File
Decedent's Estate

The fiduciary (or one of the joint fiduciaries) must file Form 1041 for a domestic estate that has:

Gross income for the tax year of $600 or more;

A beneficiary who is a nonresident alien; or

If you held a qualified investment in a qualified opportunity fund (QOF) at any time during the year, you must file your return with Form 8997 attached. See the Form 8997 instructions.

An estate is a domestic estate if it isn't a foreign estate. A foreign estate is one the income of which is from sources outside the United States that isn't effectively connected with the conduct of a U.S. trade or business and isn't includible in gross income. If you are the fiduciary of a foreign estate, file Form 1040-NR, U.S. Nonresident Alien Income Tax Return, instead of Form 1041.
Trust

The fiduciary (or one of the joint fiduciaries) must file Form 1041 for a domestic trust taxable under section 641 that has:

Any taxable income for the tax year;

Gross income of $600 or more (regardless of taxable income);

A beneficiary who is a nonresident alien; or

If you held a qualified investment in a QOF at any time during the year, you must file your return with Form 8997 attached. See the Form 8997 instructions.

Two or more trusts are treated as one trust if the trusts have substantially the same grantor(s) and substantially the same primary beneficiary(ies) and a principal purpose of such trusts is avoidance of tax. This provision applies only to that portion of the trust that is attributable to contributions to corpus made after March 1, 1984.

Isn't $15 minus $100 equal to no taxable income?