I couldn't remember the exact phrasing, so I had to look it up - it covers the argument that the first term didn't count because he might not have been officially elected. Heck, it even covers that he might have been in the office but not acting like a President. Good call by the framers of that amendment.
Amendment XXII
Section 1. No person shall be elected to the office of the President more than twice, and no person who has held the office of President, or acted as President, for more than two years of a term to which some other person was elected President shall be elected to the office of the President more than once.
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