Exhibit
      99.13





INDEPENDENT
      AUDITORS’ REPORT








To
      the
      Partners of


Creative
      Choice Homes VII, LTD





We
      have
      audited the accompanying balance sheet of Creative Choice Homes VII, LTD, [FHA
      Project No.066-35039], as of December 31, 2004, and the related statements
      of
      profit and loss, partners' equity, and cash flows for the year then ended.
      These
      financial statements are the responsibility of the Project's management. Our
      responsibility is to express an opinion on these financial statements based
      on
      our audit.





We
      conducted our audit in accordance with auditing standards generally accepted
      in
      the United States of America, the standards applicable to financial audits
      contained in Government  Auditing  Standards issued
      by the Comptroller General of the United States, and in accordance with the
      auditing standards of the U.S.  Public  Company  Accounting  Oversight  Board. Those
      standards require that we plan and perform the audit to obtain reasonable
      assurance about whether the financial statements are free of material
      misstatement. An audit includes examining, on a test basis, evidence supporting
      the amounts and disclosures in the financial statements. An audit also includes
      assessing the accounting principles used and significant estimates made by
      management, as well as evaluating the overall financial statement presentation.
      We believe that our audit provides a reasonable basis for our
      opinion.





In
      our
      opinion, the financial statements referred to above present fairly, in all
      material respects, the project financial position of Creative Choice Homes
      VII,
      LTD as of December 31, 2004, and the results of its operations, its partners'
      equity, and its cash flows for the year then ended in conformity with accounting
      principles generally accepted in the United States of America.





In
      accordance with Government  Auditing  Standards, issued
      by the Comptroller General of the United States, and the Consolidated  Audit  Guide  for  Audits  of  HUD  Programs, issued
      by the U.S. Department of Housing and Urban Development, Office of the Inspector
      General, we have also issued our report dated April 4, 2005, on our
      consideration of Creative Choice Homes VII, LTD' internal control and reports
      dated April 4, 2005 on its compliance with specific requirements applicable
      to
      major HUD programs, specific requirements applicable to Affirmative Fair Housing
      and Non-Discrimination, and specific requirements applicable to nonmajor HUD
      program transactions. Those reports are an integral part of an audit performed
      in accordance with Government  Auditing  Standards and
      should be read in conjunction with this report in considering the results of
      our
      audit.





Our
      audit
      was conducted for the purpose of forming an opinion on the basic financial
      statements taken as a whole. The accompanying supplementary information shown
      on
      pages 15 through 17 is presented for purposes of additional analysis and is
      not
      a required part of the basic financial statements of the Project. Such
      information has been subjected to the auditing procedures applied in the audit
      of the basic financial statements and, in our opinion, is fairly stated, in
      all
      material respects, in relation to the basic financial statements t en as a
      whole.





/s/
      Habif, Arogeti & Wynne, LLP


Atlanta,
      Georgia


April
      4,
      2005