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Anything below 100' at an airport is considered to be a surface operation. That means you can air taxi, hover taxi or just be there running and not need an IFR clearance.

I went through this before because we have an hospital with two helipads about 60 yards apart. The base is at one pad and the IFR departure starts at the other. So, we airtaxi to the other pad for the IFR departure.

I am really hoping the pilot in question was just trolling. There is absolutely nothing against regulation prohibiting ground and hover checks below basic VFR weather.