Zion non-profit corporation (a commonwealth of pennsylvania not for profit corporation) (the "corporation") was organized to own and operate a 94-unit apartment community in philadelphia, pennsylvania, known as zion gardens (the "community"). The corporation has entered into a housing assistance payment contract ("hap contract") with hud. The current hap contract expires october 2015 but it is expected to be renewed. The hap contract is a rent assistance program for low income families (or persons) as provided by the section 8 program of the national housing act.