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BRIGGS AND MORGAN <br />2200 FIRST NATIONAL BANK BUILDING <br />332 MINNESOTA STREET <br />SAINT PAUL, MINNESOTA 55101 <br />TELEPHONE (650 223 -6600 <br />FACSIMILE (651) 223 -6450 <br />PROFESSIONAL ASSOCIATION WRITER'S DIRECT DIAL <br />(612) 223-6421 <br />WRITER'S E -MAIL <br />March 31, 1999 mcdbri @briggs.com <br />Mr. Joel R. Hanson <br />City Administrator <br />City. of Little Canada <br />515 Little Canada Road <br />Little Canada, MN 55117 -1600 <br />Re: City of Little Canada 42(m)(2)(D) Determination Letter Requested for <br />Province Apts. (the "Project ") <br />Dear Mr. Hanson: <br />We have now reviewed the documentation submitted on behalf of Little Canada Leased <br />Housing Associates, L.L.P., a Minnesota limited liability partnership (the "Partnership ") in support <br />of its request of the City of Little Canada to issue an Internal Revenue Code Section 42(m)(2)(D) <br />letter (the "Determination Letter "). <br />Based upon our review of the relevant information, we have determined that the Partnership <br />has submitted all materials and supporting documentation required under the State of Minnesota <br />Housing Tax Credit Qualified Allocation Plan ( "QAP ")' and under the Tax Credit Usage Agreement <br />and those documents appear to be in compliance with the requirements of the QAP, the Tax Credit <br />Usage Agreement and the applicable Internal Revenue Code provisions. <br />The City itself must review the exhibits as well as the Piper Jaffray letter dated March 4, <br />1999 in making its determination that the housing credit dollar amount to be generated by renting <br />65 percent of the Project units to individuals or families whose income is 60 percent or less of the <br />area median gross income (including adjustments for family size) as determined in accordance with <br />Section 42 of the Internal Revenue Code of 1986, as amended does not exceed the amount necessary <br />for the financial feasibility of the Project and its viability as a qualified low- income housing project <br />This Project received its allocation of tax - exempt bonds from the Department of <br />Finance, pursuant to Minnesota Statutes, Section 474A.061 before January 25, 1996. Accordingly, <br />the Partnership is not required to demonstrate that the Project is eligible for not less than 25 points <br />under the QAP. <br />1035551.1 <br />rage 36RECEIVED <br />MINNEAPOLIS OFFICE • IDS CENTER • WWW.BRIGGS.COM <br />MEMBER - LEX MUNDI, A GLOBAL ASSOCIATION OF INDEPENDENT LAW FIRMS <br />