1031 Exchange question

[Tim Wilkinson]

Hello all!

I'm asking a question for my father, who is 70, and lives in SC. He owned a house in FL that used to be his primary residence, but he rented it out for last 10 years. While he rented the house out in FL, he was a renter in an apartment complex in Anderson, SC. He sold the FL house and profited a little (20K-ish).

Here is my question:

If he was not a primary homeowner, but owned an investment property, and sold it. Does he have to pay capital gains on the 20K if he purchases a primary residence with the proceeds? It seems there would be an argument for him not gaining wealth here. He literally has to put the profits towards his new purchase which will be owner occupied. 

I'm grateful to anyone who knows info that could help me help him. 

I am everything I am today because of this man. 

Thanks!