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IRS Revenue Ruling
2001-37Code Sec. 42
<<FULL TEXT>>
Low-income housing credit; satisfactory bond; "bond factor"
amounts for
the period July through September 2001. This ruling
announces the monthly
bond factor amounts to be used by taxpayers who dispose of
qualified
low-income buildings or interests therein during the period
July through
September 2001.
REV. RUL. 2001-37
In Rev. Rul. 90-60, 1990-2 C.B. 3, the Internal Revenue
Service
provided guidance to taxpayers concerning the general
methodology used by
the Treasury Department in computing the bond factor amounts
used in
calculating the amount of bond considered satisfactory by
the Secretary
under section 42(j)(6) of the Internal Revenue Code. It
further announced
that the Secretary would publish in the Internal Revenue
Bulletin a table
of "bond factor" amounts for dispositions occurring during
each calendar
month.
Rev. Proc. 99-11, 1999-1 C.B. 275, established a collateral
program as
an alternative to providing a surety bond for taxpayers to
avoid or defer
recapture of the low-income housing tax credits under
section 42(j)(6).
Under this program, taxpayers may establish a Treasury
Direct Account and
pledge certain United States Treasury securities to the
Internal Revenue
Service as security.
This revenue ruling provides in Table 1 the bond factor
amounts for
calculating the amount of bond considered satisfactory under
section
42(j)(6) or the amount of United States Treasury securities
to pledge in a
Treasury Direct Account under Rev. Proc. 99-11 for
dispositions of
qualified low-income buildings or interests therein during
the period July
through September 2001.
TABLE 1 REV. RUL. 2001-37
Monthly Bond Factor Amounts for Dispositions Expressed As a
Percentage
of Total Credits
Calendar Year Building Placed in Service
or, if Section 42(f)(1) Election Was Made,
the Succeeding Calendar Year
-----------------------------------------------------
Month of
Disposition 1987 1988 1989 1990 1991 1992 1993
----------- ---- ---- ---- ---- ---- ---- ----
Jul '01 19.30 35.47 49.02 60.48 70.18 70.27 71.68
Aug '01 19.30 35.47 49.02 60.48 70.18 70.09 71.49
Sep '01 19.30 35.47 49.02 60.48 70.18 69.91 71.31
Month of
Disposition 1994 1995 1996 1997 1998 1999 2000 2001
----------- ---- ---- ---- ---- ---- ---- ---- ----
Jul '01 72.99 74.30 75.75 77.30 79.07 80.80 82.36 83.98
Aug '01 72.80 74.10 75.55 77.10 78.86 80.60 82.19 83.98
Sep '01 72.61 73.91 75.36 76.91 78.67 80.41 82.05 83.98
For a list of bond factor amounts applicable to dispositions
occurring
during other calendar years, see: Rev. Rul. 98-3, 1998-1 C.B.
248, and
Rev. Rul. 2001-2, 2001-2 I.R.B. 255. For dispositions
occurring during the
period January through March 2001, see Rev. Rul. 2001-10,
2001-10 I.R.B.
755. For dispositions during the period April through June
2001, see Rev.
Rul. 2001-19, 2001-18 I.R.B. 1143.
DRAFTING INFORMATION
The principal author of this revenue ruling is Gregory N.
Doran of the
Office of Associate Chief Counsel (Passthroughs and Special
Industries).
For further information regarding this revenue ruling,
contact Mr. Doran
at (202) 622-3040 (not a toll-free call).
<<END RULING>>
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