I assume this is with the engine off? If not, look for vibration induced interference. If as I suspect this is with the engine off your best bet is to swap out the receiver and try that. He could for the sake of testing pull the rx antenna completely away from the heli and lay it on the ground and try it that way just to see of range improves. I don't fly JR but there has to be a reason the range is that short. He should get a solid 50 meters with collapsed tx antenna.
The best way to find a problem such as this is experimenting. Also check the crystal.
With all that said, I'd bet the rx has a problem.
Matt