Eligible Basis and Qualified Basis
IRS IRC § 42 Audit Technique Guide — Part I (Introduction and Pre-Contact Analysis) · 2026 edition · updated 2026-07-29 · United States
Compare the Maximum Qualified Basis identified on line 3a by the state agency and the eligible basis identified on line 7 by the taxpayer.
If the numbers are the same, then (1) the building was intended to be a 100% low-income building and (2) the state agency determined that it was necessary to allocate the maximum amount of credit possible to assure that the project would remain feasible throughout the 15-year compliance period.
If the eligible basis is more than the qualified basis, then either the building is a mixeduse building (both low-income and market-rate units) or the state agency determined that it was not necessary to allocate the maximum amount of credit possible to assure that the project would remain feasible throughout the 15-year compliance period.
If the eligible basis is less than the maximum qualified basis, the issue should be addressed during the audit.
If the percentage on line 3b is larger than 100%, then the eligible basis identified on line 7 has been artificially increased above the actual costs because the building is in a location that is considered difficult to develop; e.g., the costs of construction, land, and utilities are high compared to the location's Area Median Gross Income or there is a particularly high concentration of low-income individuals. The increased eligible basis increases the amount of credit available to subsidize costs that cannot be supported by debt or future cash flow from rents.
There should be a one-to-one match of Forms 8609 to Forms 8609-A filed with the tax return. Compare the eligible basis on Form 8609, line 7, to the eligible basis identified on Form 8609-A, line 1. The numbers should be the same. If the eligible basis on Form 8609-A, line 1, is less than reported on Form 8609, then a recapture event may have occurred and the issue needs to be addressed during the audit. The eligible basis on Form 8609-A, line 1, should never be larger than the eligible basis reported on Form 8609, line 7.
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Ask AI about this code▸ Contents — IRS IRC § 42 Audit Technique Guide — Part I (Introduction and Pre-Contact Analysis)
- IRC §42, Low-Income Housing Credit - Part I Introduction and P…
- Chapter 1 Introduction
- Topics
- Overview of the IRC §42 Program
- Types of Housing
- Combining with Other Tax Credits
- Computation of Allowable Annual Credit
- Eligible Basis
- Applicable Fraction
- Qualified Basis
- Applicable Percentage
- Compliance Requirements
- Credit Disallowance and Recapture
- State Housing Agency Responsibilities
- Qualified Allocation Plan (QAP)
- Allocating Credits
- Compliance Monitoring
- Reporting Noncompliance to the IRS
- Annual Report to the IRS
- IRS Responsibilities: Chief Counsel
- IRS Responsibilities: LIHC Compliance Unit
- Form 8610, with Form 8609 and Schedule A (Form 8610)
- Form 8823
- Form 8821
- IRS Responsibilities: Audits
- Summary
- Chapter 2 Pre-contact Analysis
- Introduction
- Topics
- Form 8609, Low-Income Housing Credit Allocation and Certificat…
- Amount of Credit Allocated
- Eligible Basis and Qualified Basis
- Applicable Percentage
- Type of Allocation
- Tax-Exempt Bonds
- Nonprofit Set-Aside
- Credit Period: BINs, Dates, and Elections
- Multi-Building Projects
- Minimum Set-Aside
- Property Address
- Form 8823, Low-Income Housing Credit Agencies Report of Noncom…
- Reconciliation to Forms 8609
- Rental Units
- Period of Noncompliance
- Categories of Noncompliance
- Dispositions
- Form 8609-A, Annual Statement for Low-Income Housing Credit
- Part I, Compliance Information
- Part II, Computation of Credit
- Balance Sheet
- Land Values
- Buildings and Other Depreciable Assets
- Accounts Receivable and Payable
- Schedule K and Schedule K-1
- Ownership By Individuals
- Prior and Subsequent Year Returns
- Related Returns
- Partners: Consistent Treatment
- General Partner: Additional IRC §42 Projects
- Risk Analysis
- Example 1: Estimating Potential Tax
- Initial Information Document Request
- General Information about the Taxpayer
- Tax Returns
- Eligible Basis
- Qualifying Low- Income Households
- 1st and 11th Year of the Credit Period
- Additions to Qualified Basis
- Examination of Income: Rents & Other Sources of Income
- Noncompliance
- Dispositions
- IDR & Crosswalk to Issues
- Summary
- Exhibit 2-1 IDR & Crosswalk to Issues
- General Information about the Credit Allocation
- Eligible Basis
- Qualifying Low- Income Households
- 1st and 11th Year of the Credit Period
- Additions to Qualified Basis
- Rents & Other Sources of Income (Minimum Income Probes)
- Noncompliance
- Dispositions
- Chapter 3 Audit Techniques
- Introduction
- Topics
- Interviewing Taxpayers
- Background and Financial History
- Business Practices
- Internal Controls
- Compliance with IRC §42
- Physical Maintenance
- Tenant Qualifications
- Tenant Files
- Rents
- Cash Flows
- Community Service Facilities
- Forms 8823
- Prior and Subsequent Year Tax Returns
- Large, Unusual, or Questionable Items
- Related Parties or Returns
- Touring IRC §42 Projects
- Preparing for Tour of an IRC §42 Project
- Physical Characteristics to Observe When Touring IRC §42 Proje…
- Rents
- Income Qualifying New Tenants
- Mixed-Use Projects
- Community Service Facilities
- Analyzing Results
- Case File Documentation
- Evaluating Internal Controls
- Control Environment
- Accounting System
- Control Procedures
- Testing Internal Controls
- Establishing Scope and Depth of the Audit
- Third Party Contacts
- Contacting State Agencies
- Other Third Party Contacts
- Summary