IRS Revenue Ruling
2002-8

 Code Sec. 42

<<FULL TEXT>>

Low-income housing credit; satisfactory bond; "bond factor" amounts for
the period January through March 2002. 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 January
through March 2002.


REV. RUL. 2002-8

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 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
January through March 2002.


TABLE 1 REV. RUL. 2002-8

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 1988 1989 1990 1991 1992 1993 1994
----------- ---- ---- ---- ---- ---- ---- ----
Jan '02 17.76 32.73 45.44 56.24 65.46 65.92 66.46
Feb '02 17.76 32.73 45.44 56.24 65.46 65.75 66.28
Mar '02 17.76 32.73 45.44 56.24 65.46 65.57 66.10

Month of
Disposition 1995 1996 1997 1998 1999 2000 2001 2002
----------- ---- ---- ---- ---- ---- ---- ---- ----
Jan '02 66.99 67.63 68.35 69.24 70.13 70.98 72.28 72.55
Feb '02 66.80 67.44 68.16 69.05 69.92 70.77 72.05 72.55
Mar '02 66.62 67.26 67.98 68.86 69.73 70.58 71.84 72.55


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); Rev.
Rul. 2001-2 (2001-2 I.R.B. 255); and Rev. Rul. 2001-53 (2001-46 I.R.B.
489).


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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