Comment on FR Doc # E7-11731

Document ID: IRS-2007-0092-0003
Document Type: Public Submission
Agency: Internal Revenue Service
Received Date: July 18 2007, at 05:01 PM Eastern Daylight Time
Date Posted: November 21 2007, at 12:00 AM Eastern Standard Time
Comment Start Date: June 19 2007, at 12:00 AM Eastern Standard Time
Comment Due Date: September 17 2007, at 11:59 PM Eastern Standard Time
Tracking Number: 8026aad6
View Document:  View as format xml

This is comment on Proposed Rule

Section 42 Utility Allowance Regulations Update

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Our Housing Authority not only operates Housing Choice Voucher and Public Housing programs but we also manage a low-income housing tax credit property. Because utility costs are going up a great deal the utility allowances must increase as well. When HUD sets the fair market rents the increased utility costs are part of the calculations so higher FMRs can have an off setting effect against higher utility allowances for the voucher program. However, the higher utility allowances for the LIHTC program can cause a real cash flow problem since those rents are based on income limits not FMR. I don't know what can be done about this problem. In setting utility allowances for a LIHTC property it could be useful to allow a property owner to set a date and read all the meters for tenant supplied utilities on that date then again on the same date one year later. Pictures could be taken of the meters to document the readings. Consumption averages could be calculated for each different sized units that had a full year of occupancy. The State housing agency monitoring the LIHTC program could gather and publish utility rates for each county or region that would be applied to the consumption data to produce the new utility allowances each year.

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