The National Council of State Housing Agencies (NCSHA) this week sent a letter to the Internal Revenue Service and the Department of the Treasury concerning the implementation of income averaging in low-income housing tax credit properties. The letter seeks state flexibility in establishing income-averaging guidelines and determining how to approach compliance monitoring. The letter asks the IRS to establish a procedure for HUD to calculate area-specific income limits at various designations, to update Form 8823 and to establish rules for determining the next-available-unit designation when more than one tenant in units of different income levels go over-income at the same time.