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June 5 Draft
PHASE I
$23,000,000
NEWPORT NEWS REDEVELOPMENT AND HOUSING AUTHORITY
MULTIFAMILY HOUSING REVENUE BONDS
(STUART GARDENS I APARTMENTS), SERIES 2026
TAX CERTIFICATE AND AGREEMENT
THIS TAX CERTIFICATE AND AGREEMENT (this "Tax Certificate"), dated July
__, 2026 (the "Issue Date"), is entered into by and between the Newport News Redevelopment
and Housing Authority, a political subdivision of the Commonwealth of Virginia (the "Issuer"),
Stuart Gardens Housing Partners, LP, a Virginia limited partnership (the "Borrower"), and U.S.
Bank Trust Company, National Association (the “Trustee”) in connection with the issuance by
the Issuer on the date hereof of its $23,000,000 Multifamily Housing Revenue Bonds (Stuart
Gardens I Apartments), Series 2026 (the "Bonds").
WHEREAS, on the date hereof (the "Issue Date") the Issuer is issuing the Bonds, the
proceeds of which, together with certain other available funds, are expected to be used to make a
loan to the Borrower to finance the rehabilitation, renovation, construction, improvement and
equipping of a multifamily residential rental housing development, consisting of approximately
250 one-bedroom, two-bedroom and three-bedroom affordable housing apartment units, known as
the Stuart Gardens I Apartments, located in the City of Newport News, Virginia (the "Project").
WHEREAS, under the Internal Revenue Code of 1986, as amended, the Treasury
Regulations (including Treasury Regulations issued from time to time applicable to the Bonds)
promulgated thereunder and the rulings with respect thereto, the interest paid and to be paid on
state or local governmental bonds will be excludable from gross income for federal income tax
purposes if the Issuer and certain other benefited parties comply with certain limitations and
requirements imposed on the use and operation of the facilities deemed financed or refinanced
with the Bonds and on the use and investment of proceeds, if any, of the Bonds and certain other
moneys relating to the Bonds; and
WHEREAS, the Issuer and the Borrower have determined to enter into this Tax Certificate
(including all exhibits hereto) in order to set forth certain terms and conditions relating to the use
and investment of proceeds of the Bonds and of certain other moneys relating to the Bonds in order
to assure that interest on the Bonds will be excludable from gross income for federal income tax
purposes;
NOW, THEREFORE, in consideration of the mutual covenants and undertakings set
forth herein, and other good and valuable consideration, the receipt and sufficiency of which are
hereby acknowledged, and pursuant to Section 1.148-2(b)(2) of the Treasury Regulations, the
Issuer and the Borrower hereby certify, covenant and agree in good faith as follows:Jump to an indexed page (744 of 744)