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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Member discount program primarily benefited participating businesses
A group of local employers and businesses proposed a membership program intended to encourage shopping locally. Employer members would pay annual dues so their employees could use an electronic card f…
Social club failed the nonmember-income test after suspending member dues
A self-declared section 501(c)(7) social club had suspended member dues and relied on a single income source outside its membership. The IRS examination found that the club exceeded the permitted nonm…
IRS revoked a charity for insider inurement and no substantiated exempt activity
An organization said it provided food, clothing, transportation, medical equipment, and temporary housing assistance to elderly, disabled, displaced, and recently discharged hospital patients. The IRS…
The IRS revoked a social welfare organization's exemption
The IRS revoked an organization's section 501(c)(4) tax exemption after it repeatedly failed to provide records needed for an examination. The organization also failed to file required annual and quar…
IRS revokes a treatment program's exemption for private benefit
The IRS revoked a treatment program's section 501(c)(3) status after concluding that it served private interests and allowed earnings to benefit insiders. The program charged for treatment but did not…
Baseball umpire association denied 501(c)(3) reinstatement
A local baseball umpire association applied to reinstate its section 501(c)(3) exemption after an automatic revocation for missed annual filings. The IRS found that its articles did not limit its purp…
Social club loses exemption over public hall rentals
The IRS revoked a social club's section 501(c)(7) exemption after it regularly rented its facility to the general public. The club made the hall available on Saturdays, displayed signs advertising ren…
Charity loses exemption after failing to substantiate its overseas support activity
The IRS revoked a charity's section 501(c)(3) exemption after an examination produced too little information to establish how it operated. The organization said it supported an overseas educational or…
Large endowment grant qualifies as an unusual grant
A publicly supported charity expected a large grant from an unrelated private foundation to create an endowment supporting fellowships for emerging scholars researching financial history. The donor ha…
Charity loses exemption over uncontrolled foreign spending and private benefit
The IRS revoked a charity that primarily wired funds to a separately organized foreign entity and relied on a local manager to spend them. The charity had no written agreements, did not require suppor…
Social club loses exemption over public operations and excess nonmember income
The IRS revoked a social club whose facility, bar, games, fundraisers, food sales, and event rentals were open to members and the general public. Member dues were only a small portion of revenue, whil…
Charity loses exemption after ignoring repeated examination requests
The IRS repeatedly asked a charity for financial and operational records needed to examine its continued qualification under section 501(c)(3). An initial letter was returned, but later requests were …
Franchise advertising cooperative denied business-league exemption
A group of franchisees for one company formed a marketing cooperative to pool required advertising contributions and buy sponsorships, direct mail, digital advertising, and other promotions for their …
Dissolved charity loses exemption after failing the operational test
A charity failed to provide records requested during an IRS examination, even after receiving an extension because of the global pandemic. The organization later told the IRS that it had dissolved bec…
Youth charity loses exemption after officers received personal benefits
A youth charity conducted speaking programs and camps that furthered exempt purposes, but its records showed substantial personal payments to its two remaining officers beyond reasonable compensation.…
IRS denies 501(c)(3) status to a cultural group that mainly pays members' funeral costs
An organization that promotes a particular cultural heritage applied to be recognized (actually, reinstated) as a tax-exempt charity under IRC section 501(c)(3) after losing its exemption for not fili…
IRS denies 501(c)(3) status to a group promoting trade between two countries for its member businesses
An organization applied (using the streamlined Form 1023-EZ) to be recognized as a tax-exempt charity under IRC section 501(c)(3). Its stated purpose is to be an impartial promoter of commerce, touris…
Private foundation loses exemption after failing to provide examination records
The IRS asked a private foundation to schedule an examination and provide its books, records, and activity information. The request was sent to the address shown on its return, was not returned as und…
Inactive charity loses exemption after repeated recordkeeping failures
A charity had previously failed an IRS recordkeeping review and signed an agreement to maintain source documents, legible receipts, loan records, bank statements, and other financial records. In a lat…
Political organization denied social-welfare exemption for campaign activity
An organization asserted that it qualified as a social-welfare organization under section 501(c)(4) without requesting a determination letter. It was closely affiliated with a political action committ…
Inactive charity loses exemption after failing the operational test
A charity had reported no revenue or expenses on its returns. During an examination, its director told the IRS that the organization had been inactive since its inception because it could not obtain f…
Charity loses exemption after its assets served private interests
The IRS examination report said a charity solicited tax-deductible donations but its founder used the organization’s income and assets for himself, his family, and business partners. The report descri…
IRS revokes 501(c)(7) status of a social club with excessive non-member income
A tax-exempt social club under section 501(c)(7) drew a large share of its money from non-members: banquet food and bar sales, rentals of its hall and equipment to outsiders, investment income, and re…
IRS revokes 501(c)(3) status of a non-responsive supporting organization that could not substantiate its charitable purpose
An organization had been recognized as a 501(c)(3) public charity classified as a supporting organization under section 509(a)(3), set up to support two named charities. During the audit it essentiall…
IRS revokes 501(c)(7) status of a golf and country club with excessive non-member income
A tax-exempt social club under section 501(c)(7) ran a country club and golf course that was open to the public most days of the year. The audit found the club earned substantial income from non-membe…
IRS revokes 501(c)(3) status of a dormant family private foundation for failing the operational test
A private non-operating foundation had been set up as a grantmaking family foundation, expected to fund charities chosen by its board. By the years the IRS examined, it had gone completely dormant: no…
IRS revokes 501(c)(7) status of a club whose hall and bar were open to the general public
A tax-exempt social club under section 501(c)(7) operated a clubhouse and bar that, according to its own website, were open to the general public. Much of its income came from renting the hall to non-…
IRS revokes 501(c)(3) status of a residential youth program for inurement to its director and destroyed records
A charity ran a residential program for youth with difficult behaviors, offering mentoring, outdoor activities, farm work, and counseling. The IRS revoked its 501(c)(3) exemption on two grounds. First…
IRS treats a foundation grant to a public charity as an "unusual grant" that will not undercut its public-support status
A public charity that is tax-exempt under section 501(c)(3) and classified as a publicly supported charity under sections 509(a)(1) and 170(b)(1)(A)(vi) was about to receive a large grant from a relat…
IRS denies 501(c)(3) exemption to a resident-owned manufactured-home community
A resident-owned cooperative that bought the land under a manufactured-home community, to keep lot rents low and prevent displacement, applied for 501(c)(3) charitable exemption. The IRS denied it. Th…
IRS revokes 501(c)(4) status of an employee association operating as an exclusive labor unit
An association of sworn municipal employees, recognized as tax-exempt under section 501(c)(4) as a local association of employees, was audited and lost its exemption. To qualify, such an association m…
IRS revokes 501(c)(7) status of a social club funded almost entirely by investment income
A tax-exempt social club under section 501(c)(7) charged no membership dues and drew all of its support from a stock-and-securities portfolio. Social clubs may receive no more than 35 percent of their…
IRS revokes 501(c)(3) status of an "education" charity that ran a commercial travel-package auction business
A group recognized as a 501(c)(3) educational charity said its mission was to train other nonprofits on how to run better fundraising events. In practice, the IRS found, its money came almost entirely…
IRS revokes 501(c)(7) social-club exemption for exceeding the nonmember-income limit and failing to keep required records
A social club, recognized years earlier as tax-exempt under IRC Section 501(c)(7), was audited and lost its exemption. A 501(c)(7) club is a members-only recreation group, funded mainly by member dues…
IRS denies 501(c)(3) status to a dues-based mutual-aid group that pays members' equipment-repair costs
An organization applied for 501(c)(3) charitable status using the short Form 1023-EZ. It describes itself as representing a community of haulers and offering them financial and educational help. In pr…
IRS denies 501(c)(3) status to a group maintaining a shared irrigation pipeline for a set of neighboring families
An organization applied for 501(c)(3) charitable status on the short Form 1023-EZ, describing its main activity as managing water usage for residents of a particular area. On closer review, its purpos…
IRS revokes 501(c)(3) status of a dormant supporting-organization foundation that only traded securities and made no charitable distributions
A foundation had been recognized as a 501(c)(3) public charity, specifically a Section 509(a)(3) supporting organization, meaning it existed to support one named charity. A supporting organization kee…
IRS denies 501(c)(3) status to a fee-charging gap-analysis consulting and training business
An organization applied for 501(c)(3) status on the short Form 1023-EZ, claiming educational purposes. Its main activity is consulting: it runs "gap analysis" for clients, using surveys and interviews…
IRS revokes a public charity's 501(c)(3) status where it ran a commercial café and rental operation and stopped its charitable distribution
A charity had been recognized as a 501(c)(3) public charity, the kind that must draw substantial support from the general public (Section 509(a)(1) and 170(b)(1)(A)(vi)). Its charitable purpose involv…
IRS revokes a cultural social club's 501(c)(7) status for excess public-use and rental income
A cultural social club had been recognized as tax-exempt under Section 501(c)(7), the category for members-only clubs run for pleasure and recreation. It offered members a social environment, free tut…
IRS revokes a social club's 501(c)(7) status where its only income was investment returns and it charged no dues
A social club recognized as tax-exempt under Section 501(c)(7) had a purpose of providing social and recreational activities to its members, tied to a group that once provided housing at a campus. A 5…
IRS revokes a fraternal title-holding group's 501(c)(7) status after it sold its building and kept only investment income
This organization started as a company that owned and held title to a building for a fraternal lodge. Over the decades its tax classification shifted: originally exempt as a title-holding corporation …
IRS denies 501(c)(3) status to a retirement-community firearms and shooting club that serves its members' private interests
To be a tax-exempt charity under section 501(c)(3), an organization must be operated exclusively for charitable or educational purposes and must serve the public rather than the private interests of i…
IRS revokes a fraternal chapter's 501(c)(7) social-club exemption because all its revenue came from investment income, not members
A social club exempt under section 501(c)(7) (think a fraternity chapter, country club, or hobby club) is supposed to be supported mainly by its members through dues, fees, and assessments. The law le…
IRS revokes a charity that did not substantiate educational or charitable operations
A section 501(c)(3) organization told the IRS that it would carry on educational activities, but an audit found no educational opportunities or defined charitable class. The organization provided some…
IRS revokes a social club whose outside catering income exceeded the nonmember-income limit
A section 501(c)(7) social club operated a gathering place for business executives and contracted with an outside catering company. The club received monthly revenue from that arrangement, classified …
Social club loses exemption after excessive investment and nonmember income
A membership organization devoted to genealogical and historical information had been recognized as a tax-exempt social club under IRC § 501(c)(7). Its revenue included member dues and program receipt…
Social club loses exemption after mineral income replaces member support
A family membership organization had been recognized as a tax-exempt social club under IRC § 501(c)(7). It reported no member dues in the examined years and instead received a mineral-lease signing bo…
Exemption revoked over family fundraising benefits and deficient governing documents
A membership organization used fundraising programs to support activities for participating families. It credited fundraising work to family accounts that could offset trip and other program costs, so…
Social club exemption revoked for recurring investment income
A hunting, fishing, and recreation club held a professionally managed investment fund created from a lump-sum lease payment. For several consecutive years, investment income caused the club to receive…
Exemption revoked after organization failed to substantiate its operations
A private foundation did not fully respond to repeated IRS requests for its organizing documents, activity descriptions, minutes, financial records, and other examination materials. The partial respon…
Social club exemption revoked for recurring public-event income
A social club held shows and training classes that were open to the public. Most show participants were not members, but the club did not separate member and nonmember receipts or maintain the records…
Gated homeowners association denied charitable exemption
A small gated homeowners association applied for section 501(c)(3) status even though it had previously filed homeowners-association tax returns and later said the exemption application was a mistake.…
Social club exemption revoked for recurring nonmember income
A recreational social club received nonmember income from investments, royalties, securities, and rent. Although it reported some unrelated business income, it did not report all investment or royalty…
Exemption revoked after organization ignored records requests
An exempt organization had previously been classified as a private foundation and received approval to try to terminate that status by demonstrating public support. It did not establish that it met th…
Exemption revoked for defective articles and failure to provide records
An organization had attested in its streamlined exemption application that its organizing document limited its purposes and properly dedicated its assets on dissolution. State records showed that the …
Social club exemption revoked after activities ceased and investment income exceeded limits
The IRS revoked the Section 501(c)(7) exemption of a social club that had sold the property it was formed to hold. After the sale, the organization stopped conducting its own social activities and mad…
Exemption revoked for an organization that never became active
The IRS revoked the Section 501(c)(3) status of an organization that said it had never truly been active and had no plans to begin operating. The organization had received exemption through a streamli…
Exemption revoked after charity stopped operating and withheld records
The IRS revoked the Section 501(c)(3) status of an organization that had stopped conducting exempt activities but still held a parcel of land. The organization did not provide articles of dissolution,…
Resident-owned mobile home community denied charitable status
A resident-owned manufactured-home community sought exemption under Section 501(c)(3). It owned the land and rented lots only to members who owned or occupied homes in the community, with the goal of …
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.