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Individual Supports Permanent Guidance on Median Gross Income

JUN. 4, 2020

Individual Supports Permanent Guidance on Median Gross Income

DATED JUN. 4, 2020
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From: Bragin, Mitchell J.
To:
Jones Timothy L; White David
Subject:
Revenue Procedure 2020-33
Date: Thursday, June 4, 2020 2:55:02 PM

The Revenue Procedure asks for comments regarding a permanent revenue procedure on the topic as well as the effective date.

I think that it would be a great idea to publish one revenue procedure that can be applied every year (i.e., avoid annual publication of a revenue procedure).

Things have worked well by allowing the use of either current year HUD median income numbers or the prior year HUD median income numbers.

Effective date:

The preparation of tables for statewide issuers of single family mortgage revenue bonds is tedious. Here we are, 2 months after HUD released their new median income numbers, and we are still preparing tables for the use of state housing agencies. Therefore, I would suggest that your generic revenue procedure allow the continued use of the HUD median income numbers from 2 years prior for any mortgage commitments made prior to 90 days following the date of HUD's release of the current year median income numbers. How you state this in understandable language is the trick. Try the following:

Upon HUD's release of median income numbers (the “Current Year's HUD Numbers”), those Current Year's HUD Numbers may be applied to determine Section 143(f) income limits to mortgage loans committed to mortgagors on or after the date of release of the Current Year's HUD Numbers.

Except as provided in the following paragraph, upon the release of the Current Year's HUD Numbers, the HUD median income numbers that were released during the immediately prior calendar year (the “Immediately Prior Year's HUD Numbers”) may continue to be applied to determine Section 143(f) income limits to mortgage loans committed to mortgagors on or after the date of release of the Immediately Prior Year's HUD Numbers.

Upon the release of the Current Year's HUD Numbers, the HUD median Income numbers that were released by HUD during the 2d calendar year prior to the date of release of the Current Year's HUD Numbers may continue to be applied to determine Section 143(f) income limits for mortgage loans committed to mortgagors no later than 90 days after the date of release of the Current Year's HUD Numbers.

That is what you get when a tax lawyer Boomer is asked to draft just about anything.

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