IRS ISSUES GUIDELINES FOR MORTGAGE BOND ISSUERS.
Rev. Proc. 91-17; 1991-1 C.B. 515
- Institutional AuthorsInternal Revenue Service
- Cross-Reference
26 CFR 601.201: Rulings and determination letters.
(Also Part I, Sections 25, 103, 143; 1.25-1T, 1.103-1, 6a.103A-2.)
- Code Sections
- Index Termsprivate activity bonds, mortgage revenue
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 91-848 (27 original pages)
- Tax Analysts Electronic Citation91 TNT 25-12
Obsoleted in part by Rev. Proc. 92-34 Amplified by Rev. Proc. 92-25
Rev. Proc. 91-17
SECTION 1. PURPOSE
This revenue procedure provides issuers of qualified mortgage bonds, as defined in section 143(a) of the Internal Revenue Code, and issuers of mortgage credit certificates, as defined in section 25(c), with (1) the nationwide average purchase prices for new and existing residences located in the United States, and (2) the average area purchase price safe harbor limitations for new and existing residences located in statistical areas in each state and the District of Columbia.
SEC. 2. BACKGROUND
01 Section 103(a) of the Code provides that, except as provided in section 103(b), gross income does not include interest on any state or local bond. Section 103(b)(1) provides that section 103(a) shall not apply to any private activity bond that is not a "qualified bond" within the meaning of section 141. Section 141(e) provides that the term "qualified bond" means any private activity bond if that bond (1) is a qualified mortgage bond, (2) meets the volume cap requirements under section 146, and (3) meets the applicable requirements under section 147.
02 Section 143(a)(1)(A) of the Code provides that the term "qualified mortgage bond" means a bond that is issued as part of a qualified mortgage issue. Section 143(a)(2)(A) provides that the term "qualified mortgage issue" means an issue by a state or political subdivision thereof of one or more bonds, but only if (i) all proceeds of the issue (exclusive of issuance costs and a reasonably required reserve) are to be used to finance owner-occupied residences; (ii) the issue meets the requirements of subsections (c), (d), (e), (f), (g), (h), (i), and (m)(7) of section 143; (iii) the issue does not meet the private business tests of paragraphs (1) and (2) of section 141(b); and (iv) with respect to amounts received more than 10 years after the date of issuance, repayments of $250,000 or more of principal on financing provided by the issue are used not later than the close of the first semiannual period beginning after the date the prepayment (or complete repayment) is received to redeem bonds that are part of the issue.
03 An issue of bonds meets the requirements of subsection (e) of section 143 of the Code only if the acquisition cost of each residence financed by the issue does not exceed 90 percent of the average area purchase price applicable to such residence. In the case of a targeted area residence, the acquisition cost may exceed 90 percent, but must not exceed 110 percent, of the average area purchase price. The term "average area purchase price" means, with respect to any residence, the average purchase price of single-family residences (in the statistical area in which the residence is located) that were purchased during the most recent 12-month period for which sufficient statistical information is available. Separate determinations are made for new and existing residences, and for two-, three-, and four-family residences.
04 Section 143(e)(2) of the Code provides that the determination of the average area purchase price for a statistical area shall be made as of the date on which the commitment to provide the financing is made or, if earlier, the date of the purchase of the residence.
05 Section 6a.103A-2(f)(5)(i) of the Temporary Regulations under Title II of the Omnibus Reconciliation Act of 1980 (issued under former section 103A(f), the predecessor of section 143(e)) provides that an issuer may rely upon the average area purchase price safe harbor limitations published by the Department of the Treasury for the statistical area in which a residence is located.
06 An issuer may use a limitation different from the published safe harbor limitation if the issuer has more accurate and comprehensive data. See section 6a.103A-2(f)(5)(i) of the temporary regulations. In such a case, when computing the average area purchase price for a statistical area that is a county, the issuer ordinarily must make the computation on an individual county basis and may not combine two or more counties.
07 Section 143(k)(2)(A) of the Code provides that the term "statistical area" means (i) a metropolitan statistical area (MSA), and (ii) any county (or the portion thereof) that is not within an MSA.
08 An MSA is an area that contains a city of at least 50,000 population, or an urbanized area of at least 50,000 with a total metropolitan population of at least 100,000. If an area has more than one million population and meets certain other specified requirements, it is termed a "consolidated metropolitan statistical area" (CMSA), consisting of major components recognized as "primary metropolitan statistical areas" (PMSA). See Office of Management and Budget Release No. OMB-83-20, dated June 27, 1983.
09 A state or local government may elect to exchange all or part of its qualified mortgage bond authority for authority to issue mortgage credit certificates. In general, the recipient of a mortgage credit certificate may claim a federal income tax credit equal to the product of the certificate credit rate and the interest paid or accrued during the tax year on the remaining principal of the certified indebtedness amount. Section 25(c)(2)(A)(iii)(III) of the Code provides that the indebtedness certified by mortgage credit certificates must meet the purchase price requirements under section 143(e). Thus, the purchase price of the residence financed may not exceed 90 percent of the average area purchase price (110 percent in a targeted area).
10 Average area purchase price safe harbor limitations were most recently published in Rev. Proc. 89-59, 1989-2 C.B. 771, as modified by Rev. Proc. 90-24, 1990-1 C.B. 510. Section 6.03 of Rev. Proc. 89- 59, as modified by Rev. Proc. 90-24, provides that issuers may rely on those average area purchase price safe harbor limitations until they are rendered obsolete by a new revenue procedure, such as this one. Rev. Proc. 90-51, 1990-41 I.R.B. 12, supplemented Rev. Proc. 89-59 by adding average area purchase price safe harbor limitations for Guam and Puerto Rico.
11 Section 143(f) of the Code imposes a requirement concerning the income of mortgagors for whom financing is provided under qualified mortgage bonds. Section 25(c)(2)(A)(iii)(IV) provides that the recipients of mortgage credit certificates must meet the income requirements under section 143(f). Under section 143(f)(1), this income requirement is generally met only if owner financing under a qualified mortgage bond and all certified indebtedness amounts under a mortgage credit certificate program are provided to mortgagors whose family income is 115 percent or less of the applicable median family income. However, paragraph (5) of section 143(f) generally provides for an upward adjustment of the income requirement in areas (high housing cost areas) where the ratio of the area's housing costs to the area's median income is more than 20 percent higher than the analogous ratio computed on a national basis.
12 For purposes of determining whether an area is a high housing cost area under section 143(f)(5) of the Code, the issuer of bonds or certificates must compute the housing cost/income ratio under section 143(f)(5)(D). Two of the elements that must be considered in computing the housing cost/income ratio are the average purchase prices for new and existing residences located in the United States. Section 3.01 of Rev. Proc. 89-59, sets forth the nationwide average purchase prices -- $143,400 for new residences and $114,800 for existing residences. These national average purchase prices are effective until they are rendered obsolete by a new revenue procedure, such as this one.
13 The Department of Housing and Urban Development has provided the Internal Revenue Service with estimates of average area purchase prices. These estimates are based on information from the monthly "Mortgage Interest Rate Survey" (MIRS), Part A, prepared by the Office of Thrift Supervision for the Federal Housing Finance Board (FHFB). The survey contains sales price estimates for both new and existing one-family nonfarm residences. The estimates are generally based on data for the 12 months ending August 31, 1990. However, if insufficient sales data were available for MSAs and PMSAs for the 12 months ending August 31, 1990, consideration was given to earlier 12- month periods to the extent that sufficient data were available for those periods; but no sales data before September 1, 1988, were considered. If sufficient sales price estimates were available from the 12-month periods for both new and existing residences in a statistical area, safe harbor limitations for both new and existing residences were computed and are included in this revenue procedure. If sufficient sales price estimates were available for only one category (new or existing) of residence, then a safe harbor limitation for only that category is included in this revenue procedure. If sufficient sales price data were available for neither new nor existing residences in an area, then no separate safe harbor limitations for that area is contained in this revenue procedure. Data for the areas in each state with insufficient sales price data are combined to produce an estimate for "all other areas" in the state. If the available data for a state or for "all other areas" in a state are insufficient, a regional estimate of average purchase price is used.
14 The figures provided below incorporate adjustments that compensate for the fact that the underlying data from the FHFB do not include mortgages insured by the Federal Housing Administration or loans guaranteed by the Veterans Administration.
SEC. 3. APPLICATION
01 Estimates of the average area purchase prices are set forth in section 4 below. Issuers of qualified mortgage bonds and issuers of qualified mortgage certificates ("Issuers") may rely on these estimates as safe harbor limitations to satisfy the requirements of section 143(e) of the Code. If no estimate is available for an area, the safe harbor limitation for "all other areas" of the state may be used as a substitute for the omitted category.
02 Safe harbor limitations for two- to four-family residences are equal to the appropriate average area purchase price for single- family residences multiplied by the following adjustment factor: 1.126 for two-family residences, 1.363 for three-family residences, and 1.585 for four-family residences. These adjustment factors are similar to those used for the FHA mortgage limitations.
03 The average area purchase price safe harbor limitations, which are set forth below, have not been adjusted to reflect either the 90 percent of the average area purchase price described in section 143(e)(1) of the Code or the 110 percent of the average area purchase price described in section 143(e)(5).
04 If a residence is in an MSA or PMSA, the safe harbor limitation applicable to it is the limitation of that MSA or PMSA. In particular, if a residence is in an MSA or PMSA that falls in more than one state and that is listed in section 4 under a state that is different from the state in which the residence is located, then the safe harbor limitation applicable to that residence is the limitation provided for the MSA or PMSA and not the limitation provided for all other areas in the state in which the residence is located. If sufficient data are not available for the applicable category of residence (new or existing) in the MSA or PMSA, however, then the safe harbor limitation for "all areas" or "all other areas" of the state in which the residence is actually located is used for the omitted category.
05 Issuers that receive rulings permitting them to rely on an average area purchase price limitation that is higher than the applicable safe harbor limitation in this revenue procedure may rely on that higher limitation for the purpose of satisfying the purchase price requirement for bonds sold, and bond authority exchanged for authority to issue mortgage credit certificates, not more than 30 months following the termination date of the 12-month period used by the issuer to compute the limitation.
06 When computing the housing cost/income ratio under section 143(f)(5) of the Code, issuers must use as the nationwide average purchase price for residences located in the United States figures of $150,100 for new residences and $119,100 for existing residences (based on data from a 12-month period ending August 31, 1990).
07 If, for purposes of computing the housing cost/income ratio, an issuer computes different average area purchase price limitations based on more accurate and comprehensive data, the issuer must use data from a 12-month period that does not begin earlier than March 1, 1989, or end later than February 28, 1991.
08 If, pursuant to section 6.02 of this revenue procedure, an issuer relies on the average area purchase price safe harbor limitations contained in Rev. Proc. 89-59, the issuer must use the nationwide average purchase prices set forth in Rev. Proc. 89-59 in computing the housing cost/income ratio under section 143(f)(5) of the Code. Likewise, if, pursuant to section 6.05 of this revenue procedure, an issuer relies on the nationwide average purchase price published in 89-59, the issuer may not rely on the average area purchase price safe harbor limitations published in this revenue procedure or on safe harbor limitations based on more accurate and comprehensive data unless that data is from a 12-month period that does not begin earlier than December 1, 1987, or end later than November 30, 1989.
SEC. 4. AVERAGE AREA PURCHASE PRICE SAFE HARBOR LIMITATIONS
AVERAGE AREA PURCHASE PRICE
SAFE HARBOR LIMITATIONS FOR
STATE AND AREA DESIGNATION SINGLE-FAMILY RESIDENCES
__________________________ ____________________________
NEW EXISTING
___ ________
Alabama
Birmingham MSA $170,500 $111,300
Huntsville MSA 110,200 104,200
All Other Areas 125,900 92,400
Alaska
All Areas 162,900 104,200
Arizona
Phoenix MSA 143,000 95,400
Tucson MSA N/A* 100,600
All Other Areas 180,000 91,700
Arkansas
All Areas 132,600 87,600
California
Anaheim--Santa Ana PMSA 241,300 199,500
Bakersfield MSA N/A* 100,400
Chico MSA N/A* 94,300
Fresno MSA 159,800 106,900
Los Angeles--Long Beach PMSA 212,600 185,400
Modesto MSA 144,100 115,000
Oakland PMSA 218,200 176,900
Oxnard--Ventura PMSA 254,000 205,300
Redding MSA 175,800 176,300
Riverside--San Bernardino PMSA 174,700 143,800
Sacramento MSA 184,600 140,200
Salinas--Seaside--Monterey MSA 185,000 157,800
San Diego MSA 206,100 165,700
San Francisco PMSA 256,300 230,100
San Jose PMSA 245,100 207,100
Santa Barbara--Santa Maria--
Lompoc MSA 232,100 170,700
Santa Cruz PMSA 261,600 228,300
Santa Rosa--Petaluma PMSA 209,800 177,200
Stockton MSA 172,600 117,300
Vallejo--Fairfield--Napa PMSA 184,300 149,100
Visalia--Tulare--Porterville MSA N/A* 79,200
All Other Areas 176,500 144,500
Colorado
Boulder--Longmont PMSA N/A* 149,900
Colorado Springs MSA N/A* 127,300
Denver PMSA N/A* 118,100
Fort Collins--Loveland MSA N/A* 95,200
All Other Areas 152,500 107,400
Connecticut
Danbury PMSA N/A* 184,000
Hartford PMSA 181,100 143,400
New Haven--Meriden MSA 191,000 150,600
Waterbury MSA N/A* 136,100
All Other Areas 198,400 151,200
Delaware
Wilmington PMSA 132,700 91,200
All Other Areas 138,800 81,900
District of Columbia
Washington MSA 216,000 165,200
Florida
Bradenton MSA N/A* 77,400
Daytona Beach MSA 100,400 73,600
Fort Lauderdale--Hollywood--
Pompano Beach PMSA 183,900 94,800
Fort Myers--Cape Coral MSA 122,100 106,200
Fort Pierce MSA 112,500 82,000
Jacksonville MSA 128,300 95,400
Lakeland--Winter Haven MSA 86,600 77,500
Melbourne--Titusville--Palm Bay MSA 104,800 92,500
Miami--Hialeah PMSA 122,200 119,300
Orlando MSA 107,300 98,500
Sarasota MSA 136,700 95,600
Tallahassee MSA N/A* 88,300
Tampa--St. Petersburg--Clearwater
MSA 127,600 86,300
West Palm Beach--Boca Raton--
Delray Beach MSA 164,000 116,600
All Other Areas 102,300 84,400
Georgia
Atlanta MSA 169,500 130,100
Augusta MSA 135,400 85,500
Savannah MSA N/A* 76,400
All Other Areas 102,500 79,400
Hawaii
Honolulu MSA 244,600 211,500
All Other Areas 220,600 164,100
Idaho
All Areas 160,300 102,200
Illinois
Aurora--Elgin PMSA 175,200 120,400
Bloomington--Normal MSA N/A* 57,500
Chicago PMSA 160,100 116,200
Decatur MSA N/A* 50,800
Joliet PMSA 150,400 103,700
Kankakee MSA N/A* 40,100
Lake County PMSA 167,900 152,200
Peoria MSA N/A* 52,300
Rockford MSA N/A* 60,100
Springfield MSA N/A* 60,600
All Other Areas 84,600 45,200
Indiana
Elkart--Goshen MSA N/A* 72,200
Evansville MSA N/A* 54,100
Fort Wayne MSA 139,600 79,500
Gary--Hammond PMSA 148,600 57,800
Indianapolis MSA 137,500 92,600
South Bend--Mishawaka MSA N/A* 93,600
All Other Areas 93,900 55,300
Iowa
Davenport--Rock Island--Moline MSA N/A* 60,800
Des Moines MSA N/A* 83,000
Sioux City MSA N/A* 54,600
All Other Areas 97,600 55,300
Kansas
Lawrence MSA N/A* 65,100
Topeka MSA N/A* 69,400
Wichita MSA 124,700 76,600
All Other Areas 85,700 63,600
Kentucky
Louisville MSA 158,500 86,300
All Other Areas 103,500 47,800
Louisiana
Baton Rouge MSA N/A* 64,700
New Orleans MSA N/A* 66,300
All Other Areas 145,400 67,800
Maine
Portland MSA N/A* 160,300
All Other Areas 128,400 110,100
Maryland
Baltimore MSA 177,400 124,100
Cumberland MSA N/A* 69,200
Hagerstown MSA N/A* 109,000
All Other Areas 110,100 75,500
Massachusetts
Boston PMSA 190,100 150,300
Brockton PMSA N/A* 134,500
Fall River PMSA 136,100 131,600
Lawrence--Haverhill PMSA 182,300 148,300
Lowell PMSA N/A* 147,900
Salem--Gloucester PMSA N/A* 145,600
All Other Areas 175,000 128,500
Michigan
Ann Arbor PMSA 175,800 102,400
Battle Creek MSA N/A* 65,600
Benton Harbor MSA N/A* 75,100
Detroit PMSA 143,100 95,700
Flint MSA N/A* 73,700
Grand Rapids MSA 125,300 80,700
Jackson MSA N/A* 53,800
Kalamazoo MSA 121,700 73,700
Lansing--East Lansing MSA 127,600 75,500
Saginaw--Bay City--Midland MSA 117,400 65,800
All Other Areas 84,400 55,400
Minnesota
Minneapolis--St. Paul MSA N/A* 122,300
All Other Areas 133,700 112,800
Mississippi
Biloxi--Gulfport MSA N/A* 47,200
Jackson MSA N/A* 88,100
All Other Areas 91,500 62,600
Missouri
Kansas City Missouri--Kansas MSA 145,300 91,600
St. Louis MSA 96,000 95,900
All Other Areas 80,700 39,200
Montana
All Areas 124,700 95,500
Nebraska
Lincoln MSA N/A* 65,800
Omaha MSA N/A* 70,400
All Other Areas 103,600 63,500
Nevada
Las Vegas MSA 154,500 109,800
Reno MSA N/A* 159,600
All Other Areas 153,700 142,400
New Hampshire
All Areas 168,000 112,300
New Jersey
Atlantic City MSA 151,100 103,500
Bergen--Passaic PMSA 191,100 183,700
Jersey City PMSA N/A* 120,800
Middlesex--Somerset--Hunterdon PMSA 218,300 142,400
Monmouth--Ocean PMSA 230,800 138,200
Newark PMSA 200,300 175,200
Trenton PMSA N/A* 105,400
All Other Areas 138,100 110,600
New Mexico
All Areas 132,600 83,700
New York
Albany--Schenectady--Troy MSA N/A* 118,200
Buffalo PMSA N/A* 94,000
Nassau--Suffolk PMSA 195,800 165,500
New York City PMSA 198,300 168,400
Niagara Falls PMSA N/A* 68,000
Orange County PMSA N/A* 137,900
Poughkeepsie MSA N/A* 129,600
Rochester MSA 142,900 96,400
Syracuse MSA 131,400 92,000
All Other Areas 133,500 93,900
North Carolina
Charlotte--Gastonia--Rock Hill MSA 137,500 95,200
Greensboro--Winston-Salem--High
Point MSA 133,500 81,000
Raleigh--Durham MSA 140,800 122,400
All Other Areas 110,500 73,400
North Dakota
All Areas 124,700 95,500
Ohio
Akron PMSA 119,500 86,900
Canton MSA 111,200 64,600
Cincinnati PMSA 143,600 87,100
Cleveland PMSA 124,500 85,700
Columbus MSA 119,700 77,500
Dayton--Springfield MSA 154,400 77,400
Hamilton--Middletown PMSA N/A* 98,400
Lorain--Elyria PMSA 115,000 75,600
Toledo MSA N/A* 71,000
Youngstown--Warren MSA 92,500 55,300
All Other Areas 89,400 66,700
Oklahoma
Oklahoma City MSA N/A* 94,700
Tulsa MSA N/A* 94,700
All Other Areas 132,600 93,000
Oregon
Eugene--Springfield MSA N/A* 85,700
Medford MSA N/A* 86,100
Portland PMSA 154,600 96,200
Salem MSA N/A* 67,600
All Other Areas 114,000 74,000
Pennsylvania
Allentown--Bethlehem MSA 136,400 112,700
Erie MSA N/A* 66,500
Harrisburg--Lebanon--Carlisle MSA 144,000 75,200
Lancaster MSA 122,800 N/A*
Philadelphia PMSA 143,000 115,700
Pittsburgh PMSA 131,900 82,100
Reading MSA 114,200 79,900
Scranton--Wilkes-Barre MSA 118,200 69,000
State College MSA N/A* 78,600
Williamsport MSA N/A* 45,500
York MSA 119,900 90,100
All Other Areas 102,600 66,000
Rhode Island
Pawtucket--Woonsocket--Attleboro
PMSA 163,700 124,000
Providence PMSA N/A* 106,400
All Other Areas 164,900 131,100
South Carolina
Charleston MSA N/A* 99,200
Columbia MSA N/A* 115,100
Greenville--Spartanburg MSA 125,300 73,800
All Other Areas 128,400 93,400
South Dakota
All Areas 124,700 95,500
Tennessee
Chattanooga MSA 88,000 67,700
Johnson City--Kingsport--Bristol MSA N/A* 63,400
Knoxville MSA 124,400 115,100
Memphis MSA 128,500 104,500
Nashville MSA 135,700 117,200
All Other Areas 87,100 66,300
Texas
Austin MSA N/A* 117,200
Dallas PMSA 157,200 124,400
Fort Worth--Arlington PMSA N/A* 104,100
Houston PMSA 124,900 106,700
San Antonio MSA N/A* 107,200
All Other Areas 120,200 85,200
Utah
Salt Lake City--Ogden MSA N/A* 104,900
All Other Areas 135,400 103,100
Vermont
Burlington MSA N/A* 113,500
All Other Areas 128,400 110,100
Virginia
Norfolk--Virginia Beach--
Newport News MSA 164,000 137,300
Richmond--Petersburg MSA 148,100 116,600
All Other Areas 116,300 91,700
Washington
Seattle PMSA 201,100 139,200
Spokane MSA N/A* 81,500
Tacoma PMSA 147,600 106,200
Vancouver PMSA N/A* 97,900
All Other Areas 152,700 90,300
West Virginia
All Areas 140,700 42,800
Wisconsin
Eau Claire MSA N/A* 67,100
La Crosse MSA N/A* 66,000
Madison MSA 122,900 N/A*
Milwaukee PMSA 143,200 100,100
Racine PMSA N/A* 63,100
All Other Areas 98,900 67,000
Wyoming
All Areas 124,700 95,500
* Not available. The safe harbor limitation for all other areas of the state in which the residence is actually located may be used.
SEC. 5. EFFECT ON OTHER REVENUE PROCEDURES
Rev. Proc. 89-59, as modified by Rev. Proc. 90-24 and supplemented by Rev. Proc. 90-51, is obsolete except as provided in sections 6.02, 6.03, and 6.05 of this revenue procedure.
SEC. 6. EFFECTIVE DATES
01 Issuers may rely on the average area purchase price safe harbor limitations contained in this revenue procedure for commitments to provide financing that are made, or (if the purchase precedes the financing commitment) for residences that are purchased, in the period specified in the following sentence. The period begins on February 19, 1991, the date of publication of this revenue procedure in the Internal Revenue Bulletin, and ends on the date as of which these safe harbor limitations are rendered obsolete by a new revenue procedure.
02 Notwithstanding section 5 of this revenue procedure, issuers may continue to rely on the average area purchase price safe harbor limitations contained in Rev. Proc. 89-59 for mortgages financed with proceeds of bonds sold, or for certificates issued with respect to bond authority exchanged, before March 21, 1991, the date 30 days after publication of this revenue procedure in the Internal Revenue Bulletin, if the commitments to provide financing for the mortgages are made on or before May 21, 1991, the date 91 days after publication of this revenue procedure in the Internal Revenue Bulletin.
03 Issuers may continue to rely on the average area purchase price safe harbor limitations for the Commonwealth of the Northern Mariana Islands as added to Rev. Proc. 85-42, 1985-2 C.B. 496, by Rev. Proc. 87-19, 1987-1 C.B. 712, and for Guam and Puerto Rico, as added to Rev. Proc. 89-59 by Rev. Proc. 90-51, 1990-41 I.R.B. 12, until those safe harbor limitations are rendered obsolete by a new revenue procedure.
04 Issuers must use the nationwide average purchase price limitations contained in this revenue procedure for commitments to provide financing that are made, or (if the purchase precedes the financing commitment) for the residences that are purchased, in the period beginning on FEBRUARY 19, 1991, and ending on the date as of which these national and average area purchase prices are rendered obsolete by a new revenue procedure.
05 Notwithstanding section 6.04 of this revenue procedure, issuers may continue to rely on the nationwide average purchase prices as set forth in section 3.01 of Rev. Proc. 89-59 with respect to bonds sold, and bond authority exchanged for authority to issue mortgage credit certificates, before MARCH 21, 1991, if the commitments to provide financing for the mortgages and the commitments to issue the certificates are made on or before MAY 21, 1991.
DRAFTING INFORMATION
The principal author of this revenue procedure is Patricia M. Monahan of the Office of Assistant Chief Counsel (Financial Institutions and Products). For further information regarding this revenue procedure contact Ms. Monahan on (202) 566-4414 (not a toll- free call).
- Institutional AuthorsInternal Revenue Service
- Cross-Reference
26 CFR 601.201: Rulings and determination letters.
(Also Part I, Sections 25, 103, 143; 1.25-1T, 1.103-1, 6a.103A-2.)
- Code Sections
- Index Termsprivate activity bonds, mortgage revenue
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 91-848 (27 original pages)
- Tax Analysts Electronic Citation91 TNT 25-12