IRS Written Determinations
Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.
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IRS revokes a nonprofit's 501(c)(3) status after it produced no records for an audit; its charter had lapsed and been reinstated
This is the IRS's final determination revoking a nonprofit corporation's tax-exempt status under section 501(c)(3). The organization was formed by three incorporators, and its articles were adequate (…
IRS revokes a one-director nonprofit's 501(c)(3) status after it produced no records for an audit
This is the IRS's final determination revoking a nonprofit corporation's tax-exempt status under section 501(c)(3). The organization was formed by a single incorporator who was also its only listed di…
IRS revokes a nonprofit's 501(c)(3) status after it produced no records for an audit and was administratively dissolved
This is the IRS's final determination revoking a nonprofit corporation's tax-exempt status under section 501(c)(3). The organization's articles were adequate (a section stated it was organized exclusi…
IRS revokes a nonprofit's 501(c)(3) status after it ignored an audit; its charter had lapsed and been reinstated
This is the IRS's final determination revoking a nonprofit corporation's tax-exempt status under section 501(c)(3). The organization's articles were adequate (an attachment limited its purposes to 501…
IRS revokes a nonprofit's 501(c)(3) status after it acknowledged an audit but produced no records
This is the IRS's final determination revoking a nonprofit corporation's tax-exempt status under section 501(c)(3). The organization's articles of incorporation were adequate (they restricted its acti…
IRS revokes a nonprofit's 501(c)(3) status after it refused to produce records for an audit
This is the IRS's final determination revoking a nonprofit corporation's tax-exempt status under section 501(c)(3). Unlike some revocations in this series, this organization's articles of organization…
IRS revokes a nonprofit's 501(c)(3) status after it ignored an audit and never filed a required charter amendment
This is the IRS's final determination revoking a nonprofit corporation's tax-exempt status under section 501(c)(3). The organization, whose name hinted at a link to a well-known charity network (it ha…
IRS denies 501(c)(3) status to a chamber of commerce because it operates for its members' common business interests
A small-town chamber of commerce applied to be recognized as a tax-exempt charity under section 501(c)(3). It had once held 501(c)(3) status through a streamlined Form 1023-EZ, but lost it automatical…
IRS denies 501(c)(3) status to a technology-research consortium because it operates as a fee-for-service trade or business
An organization applied to be recognized as a tax-exempt charity under section 501(c)(3). It described itself as an "incubator" or consortium that links organizations needing research done with those …
202334018: IRS revokes a nonprofit's 501(c)(3) status where its activities were fundraising and gaming, and it had gone inactive
A nonprofit corporation organized for charitable and scientific purposes (educating youth and the public, and raising money for related causes) had its § 501(c)(3) exempt status revoked. During the ye…
202334017: IRS revokes a group's 501(c)(3) status for paying "scholarships" only to members who worked its concession stands
An organization that had been recognized as a § 501(c)(3) public charity lost that status after an audit. Its main activity was supplying volunteers to work concession-stand-type events in exchange fo…
202334016: IRS revokes a youth-sports booster group's 501(c)(3) status for running individual fundraising accounts
A youth-sports booster organization had its § 501(c)(3) tax-exempt status revoked. Its main activity was fundraising, but it ran the money through individual accounts: after each fundraiser, the net p…
IRS denies 501(c)(6) business-league status to a users' group for one brand of gas-turbine power plant
An organization applied for recognition as a tax-exempt business league under section 501(c)(6). It is a users' group organized around one manufacturer's ("Z") land and marine aeroderivative gas-turbi…
IRS denies 501(c)(4) status to a subdivision road-maintenance association operated for its members
An organization applied for recognition as a tax-exempt social welfare organization under section 501(c)(4). It is a nonprofit mutual benefit corporation whose sole purpose is to maintain a dead-end r…
IRS denies 501(c)(3) status to a car club operated for social and recreational purposes
An organization applied for recognition as a tax-exempt charity under section 501(c)(3). It is a car club with social, educational, and training activities: it organizes road rallies, car shows, repai…
IRS denies 501(c)(3) status to a group formed to fund equipment for the founder's disabled grandson
An organization applied for recognition as a tax-exempt charity under section 501(c)(3). Its founder's grandson, who is severely autistic and has special needs, had aged out of a former facility and w…
IRS denies 501(c)(3) status to a members' business association that promotes its members' commercial interests
An organization applied for recognition as a tax-exempt charity under section 501(c)(3), describing itself as a group that increases members' knowledge, promotes best practices and higher business sta…
IRS denies 501(c)(8) fraternal-society exemption to a one-member online order not operating under the lodge system
An organization applied for recognition as a tax-exempt fraternal beneficiary society under section 501(c)(8), the category for lodge-based fraternal orders (like the Elks or Masons) that pay life, si…
IRS denies 501(c)(3) status to a group formed to pay one board member's child's medical bills
An organization applied for recognition as a tax-exempt charity under section 501(c)(3). Its sole stated purpose was to raise and receive funds to pay the medical bills of a single minor child who suf…
IRS denies 501(c)(3) status to a family reunion association that serves its own members
An unincorporated group applied for recognition as a tax-exempt charity under section 501(c)(3), describing itself as a not-for-profit dedicated to providing an organized space for family reunion even…
IRS denies 501(c)(3) status to a family-controlled media and services company operated for its founder's benefit
An organization applied to be recognized as a tax-exempt charity under section 501(c)(3). It described itself as a family foundation and holding company built around its founder (referred to as "D") a…
IRS denies 501(c)(4) social-welfare status to a nonprofit pharmacy-benefit manager converting from a for-profit
An organization applied to be recognized as a tax-exempt social welfare organization under section 501(c)(4). It planned to run a pharmacy-benefit and pharmacy-services administration business, buying…
IRS revokes a charity's 501(c)(3) exemption for operating as a conduit in an abusive donated-LLC-interest tax scheme
A public charity recognized under section 501(c)(3) had its exemption revoked after an IRS examination. Its main assets and revenue came from donated interests in dozens of limited liability companies…
IRS denies 501(c)(3) charity status to a recreational soccer-league organization
An organization that runs youth and adult soccer leagues, already tax-exempt as a 501(c)(7) social club, applied to be recognized as a 501(c)(3) charity, a status that would let donors deduct their gi…
Private foundation could transfer all assets to a commonly controlled foundation
Two private foundations controlled by the same trustees planned to consolidate by having one foundation transfer all of its assets to the other without consideration. The IRS ruled that the transfer q…
Foundation could transfer all assets and terminate without excise tax
A private foundation planned to consolidate with another foundation controlled by the same trustees by transferring all of its assets without receiving consideration. The IRS ruled that the transfer w…
Exemption was revoked after incomplete records prevented verification
A Section 501(c)(3) organization recognized through Form 1023-EZ was selected for examination. State records showed involuntary dissolution, and the articles supplied during the audit lacked the requi…
Fundraising for one person's medical bills served a private interest
An organization applied for Section 501(c)(3) status with the stated purpose of raising money to pay one named person's breast cancer treatment expenses. Its planned activities were a local benefit an…
Missing records and articles led to retroactive revocation
A Section 501(c)(3) organization was examined to determine whether its activities and finances remained consistent with exempt status. It provided descriptions of activities, revenue material, and som…
Neighborhood property services did not qualify as a social club
A neighborhood property-owners association applied for exemption as a Section 501(c)(7) social club. It maintained privately owned residential streets, boat docks, boat ramps, and common areas, and it…
One nonmember-heavy annual event did not sustain social-club exemption
A social club's principal activity was one annual food, drink, raffle, and fellowship event, with only two board meetings at other times. Members and guests paid the same amount, members could invite …
Record retailer denied Section 501(c)(3) status
An organization applied for Section 501(c)(3) status while operating retail record sales in person and online. It said its purpose included buying and selling records, conducting community events, pay…
Property-management club loses Section 501(c)(7) status
A social club owned and managed property containing a lodge and cottages used exclusively by certain members. Its meetings and activities focused on property maintenance and management, while many cot…
Fraternal membership group denied Section 501(c)(3) status
An unincorporated association affiliated with a fraternal organization applied for Section 501(c)(3) status. Its charter contained no stated corporate purpose, and the group described itself as a soci…
Free charter-school meal program advances education
A section 501(c)(3) organization operated public charter schools and served as a state-certified School Food Authority. It expanded its meal program to help unrelated tax-exempt charter schools satisf…
IRS revokes a nonprofit's 501(c)(3) status for private benefit from bargain-sale deals and the president's personal use of funds
The IRS revoked a small charity's tax-exempt status under section 501(c)(3), effective January 1, 2018. On audit, the IRS found the organization spent much of its effort on real-estate "bargain sale" …
IRS revokes a small charity's 501(c)(3) status because vehicle expenses inured to its CEO
The IRS revoked a small nonprofit's tax-exempt status under section 501(c)(3). The group had run a residential guidance home, then sold that property and shifted to outreach and education, and it larg…
IRS revokes a dormant private foundation's 501(c)(3) status for never operating for exempt purposes
The IRS revoked a private foundation's tax-exempt status under section 501(c)(3). The foundation was set up by a declaration of trust and was recognized as exempt after filing a streamlined Form 1023-…
Exemption denied for commercial software development and private benefit
An organization sought section 501(c)(3) status for developing and supporting an open-source software platform, funding related research and applications, publishing educational materials, and making …
Exemption denied to an estate-planning member association
An association of estate-planning professionals applied for section 501(c)(3) status after filing Form 1023-EZ. Its activities included meetings with professional speakers, information about developme…
Swim-team booster club denied social-club exemption
A voluntary association of parents and guardians of high school varsity swimmers and divers applied for exemption as a social club under section 501(c)(7). It raised funds through local business promo…
Private dock owners association denied social-welfare exemption
A dock owners association applied for exemption as a social-welfare organization under section 501(c)(4). Its members were owners of specified residential lots, and annual assessments funded maintenan…
Social-club exemption revoked for recurring public-use income
The IRS revoked a section 501(c)(7) social club's exemption after finding that it made its facilities available to the general public and repeatedly earned too much income from nonmembers. The club di…
Youth baseball LLC denied exemption under LLC organizational rules
The IRS denied section 501(c)(3) status to a limited liability company that planned to train youth for baseball competitions and teach discipline, sportsmanship, teamwork, respect, and integrity. The …
Exemption revoked after organization failed to produce audit records
The IRS revoked an organization's section 501(c)(3) exemption because it did not provide records requested during an examination. The IRS sent examination correspondence to several addresses and indiv…
Family reunion organization denied social-club exemption
The IRS denied section 501(c)(7) exemption to an organization formed to continue one family's reunions. Membership was limited to descendants of a family member, and a privately owned family LLC was e…
Economic-development group denied 501(c)(3) status
An organization created by the officers of a Section 501(c)(6) business league sought Section 501(c)(3) status to fund and perform local economic-development work. The IRS found that its articles fail…
501(c)(3) denied to a members' group offering discounted insurance and career promotion to its industry members
An organization applied for 501(c)(3) charitable status using the short Form 1023-EZ, describing its mission as providing members with health, life, or disability insurance and financial planning. Whe…
IRS revokes a senior social club's 501(c)(7) exemption for inadequate records and excess nonmember income
The IRS revoked the tax-exempt status of a small social club that ran a gathering place for senior citizens. The club had been recognized under section 501(c)(7), which covers social and recreation cl…
IRS revokes a senior social club's 501(c)(7) exemption for charging no dues and keeping no records (companion to 202321015)
The IRS revoked the tax-exempt status of a small social club that ran a gathering place for senior citizens. The club had been recognized under section 501(c)(7), which covers social and recreation cl…
IRS revokes a youth-sports charity's 501(c)(3) status after it went inactive
The IRS revoked the 501(c)(3) charitable exemption of a nonprofit that had run a youth sports league for underprivileged children, offering free spots, player scholarships, and equipment to families w…
IRS revokes an arts-philanthropy charity whose main activity was investing in private secured loans
The IRS revoked the 501(c)(3) exemption of a nonprofit that had been incorporated to "promote philanthropy within the community through the Arts" and was recognized as a public charity after filing a …
IRS revokes an inactive educational private foundation and asserts a 4942 excise tax in the alternative
The IRS revoked the 501(c)(3) exemption of a nonprofit that had been organized to bring technology into schools (providing infrastructure, software, hardware, and support services to enhance education…
IRS revokes a scholarship charity whose incorporation papers lacked a purpose limitation and dissolution clause
The IRS revoked the 501(c)(3) exemption of a charity that awards scholarships to students at a specific school, not because of what it did, but because of what its organizing paperwork left out. To be…
IRS revokes a 501(c)(4) civic group that mainly ran a bar and gaming room for a related veterans post
The IRS revoked the 501(c)(4) social-welfare exemption of a civic organization whose main activity was running a bar and a gaming room (pull-tabs and lottery-type games) for the members of a related v…
IRS revokes a members' club's 501(c)(3) status because its activities were primarily social and recreational
The IRS revoked the 501(c)(3) exemption of a members' club that had been organized around promoting a standard and educating people about care requirements (its articles simply say it operates "as a n…
IRS revokes a 501(c)(3) that never responded to the audit or produced records
The IRS revoked the 501(c)(3) exemption of an organization that simply did not cooperate with its audit. The audit report walks through months of certified letters and phone calls to the group's presi…
IRS revokes a members-only horse boarding club for serving private, not public, interests
The IRS revoked the 501(c)(3) exemption of an organization that runs a horse boarding facility for its own club members. The group collects dues and fees from members to cover operating costs (grounds…
IRS revokes a charity that ran a for-profit coffee shop instead of its promised training program
The IRS revoked the 501(c)(3) exemption of an organization that had been recognized on the promise that it would run in-house training programs and employment for survivors of a particular hardship (c…
501(c)(3) status revoked for failing to respond to an audit and for defective organizing documents
The IRS revoked a group's recognition as a tax-exempt charity under section 501(c)(3). The organization was selected for audit, but it never provided the records the IRS repeatedly asked for. The exam…
What these documents are
- Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
- Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
- Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
- Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
- Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.