902 Jennings Street Housing Development Fund Corporation

“Election not to be treated as a tax-exempt entity taxpayer: 902 jennings street managing member inc. Ein: 38-4029033 in lieu of attaching the election made by the managing member, the nonprofit organization is including the following note disclosure regarding the section 168(h)(6)(f) election: the taxpayer, a for-profit subsidiary of new destiny housing, 902 jennings street owner, llc (ein: 82-0874822) and a not-for-profit organization, hereby elects under internal revenue code section 168(h)(6)(f)(ii) as a tax exempt controlled entity: (1) not to be treated as a tax-exempt entity for purposes of internal revenue code sections 168(h)(5) and (6), and (2) to treat any gain recognized by its tax-exempt parent on any disposition of an interest in it (and to treat any dividends or interest received or accrued by its tax-exempt parent from it) as unrelated business taxable income under code section 511. This election shall apply to all of the company's property for the year that property is placed in service and all subsequent years. The company is entitled to make this election because it is a tax-exempt controlled entity that is timely filing the election.”

“The organization is amending its june 30, 2020 form 990-ez to replace the accountant's certification for the 168(h)(6)(f) election with a copy of the election previously made by the managing member.”