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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Cemetery denied charitable status because it served private interests
An organization applied for Section 501(c)(3) status to operate and maintain a cemetery and sell burial plots. Its organizing document stated that cemetery operation was its purpose, and its only acti…
Exemption revoked when claimed foreign charity work could not be verified
The IRS revoked the Section 501(c)(3) status of an organization that claimed to build charitable and educational facilities in another country. Its returns did not describe those foreign activities, i…
Boat condominium denied social-club exemption
A boat-condominium operator applied for exemption as a Section 501(c)(7) social club. Its recurring activities included boat storage and retrieval, marina maintenance and repairs, fuel sales, member a…
Local business-promotion group denied charitable status
A local organization applied for Section 501(c)(3) status while describing its mission as promoting business activity in its community. It sponsored teacher recognition, children’s events, community c…
Grantmaking charity revoked after loss of corporate status and public support
The IRS revoked the Section 501(c)(3) status of a grantmaking organization whose nonprofit corporate status had been revoked by its state of incorporation. Despite repeated requests, the organization …
IRS denies 501(c)(3) status to an agricultural research and processing facility that substantially serves private commercial interests
An organization applied for 501(c)(3) status saying it was formed for scientific and educational purposes to promote agricultural production. In practice it planned to build and run a specialty proces…
IRS denies 501(c)(3) status to a members-only funeral-benefit mutual-aid group that serves its members' private interests
An unincorporated nonprofit association applied for 501(c)(3) charitable status using the streamlined Form 1023-EZ. It operates as a members-only mutual-aid fund: members pay a monthly fee, register t…
IRS revokes a "low-income housing" nonprofit that ran a commercial home-flipping business and funneled money to the founder's family
A nonprofit told the IRS it existed to create homeownership for low-income and disadvantaged people. On audit, the IRS found it mostly bought foreclosed houses through a bank-transfer program, rehabil…
Final denial of 501(c)(3) exemption to a vintage sports-car enthusiast club operated for social purposes
A membership club built around a particular vintage sports car (referred to only as "D") applied for charitable tax-exempt status under section 501(c)(3) using the short Form 1023-EZ. The club runs dr…
Revocation of 501(c)(3) status for failing the operational test and not keeping or producing records
The IRS revoked the tax-exempt status of a charity that had been recognized under section 501(c)(3) as a public charity. The organization's stated purpose was to help poor and underprivileged children…
Revocation of 501(c)(3) status where training-fee income passes through to a for-profit run by the director
The IRS revoked the tax-exempt status of an organization that had been recognized under section 501(c)(3) and treated as a public charity under section 509(a)(2). The group collected training fees fro…
Revocation of 501(c)(7) social-club exemption for public use of facilities and excess nonmember income
The IRS revoked the tax-exempt status of a social club recognized under section 501(c)(7). A 501(c)(7) club is meant to be supported mainly by its members and operated substantially for the pleasure a…
Revocation of 501(c)(7) social-club exemption for investment income exceeding the nonmember limit
The IRS revoked the tax-exempt status of a members' club recognized under section 501(c)(7). The club's stated purpose was educating members in the safe handling of firearms and conservation, and memb…
Revocation of 501(c)(7) social-club exemption where endowment investment income exceeded the nonmember limit
The IRS revoked the tax-exempt status of a family genealogical society recognized under section 501(c)(7). The society existed to research and publish the history and genealogy of families sharing a s…
Revocation of 501(c)(3) status for failure to produce records for audit
The IRS revoked the tax-exempt status of an organization that had been recognized under section 501(c)(3) after filing the short Form 1023-EZ. When the IRS selected the group for a routine audit to co…
Revocation of 501(c)(7) social-club exemption for living on investment income and lacking individual membership
The IRS revoked the tax-exempt status of a social club recognized under section 501(c)(7). The club ran a social hall for a fraternal society, letting members use it for meetings, lectures, and meals,…
Revocation of a 509(a)(3) supporting organization for private benefit, inflated gift-in-kind reporting, and illegal fundraising practices
The IRS revoked the tax-exempt status of a supporting organization recognized under section 509(a)(3), a type of charity that exists to support one or more specified public charities. This organizatio…
Final revocation of a social club's 501(c)(7) exemption for too much investment and nonmember income
The IRS issued a final adverse determination stripping a small recreational social club of its self-declared tax-exempt status under IRC Section 501(c)(7). A 501(c)(7) club stays exempt only if member…
501(c)(3) exemption revoked for inadequate records and failing the operational test
The IRS revoked a charity's tax-exempt status under IRC Section 501(c)(3), retroactive to a stated effective date. The organization was formed to provide educational programs about the benefits of ass…
IRS revokes a purported charity that ran bargain-sale real-estate deals, kept no charitable records, and funneled excess benefits to its president through undisclosed controlled companies
The IRS revoked a nonprofit's 501(c)(3) exemption after an audit found it operated as a real-estate business, not a charity. According to the examination, the organization had obtained its exempt stat…
501(c)(7) social club revoked for recurring nonmember rental income over the threshold
The IRS revoked a recreational club's tax-exempt status as a social club under IRC Section 501(c)(7). A 501(c)(7) club must be supported substantially by its members and can take in only limited outsi…
501(c)(8) fraternal society's exemption revoked for failing to produce records
The IRS revoked the tax-exempt status of a fraternal beneficiary society described in IRC Section 501(c)(8). The reason was recordkeeping, not the group's fraternal purpose. Every exempt organization …
501(c)(3) scholarship foundation revoked for awarding scholarships to a related club's employees
The IRS revoked a scholarship foundation's tax-exempt status under IRC Section 501(c)(3). The foundation was affiliated with a social club exempt under Section 501(c)(7), and it awarded almost all of …
501(c)(3) foundation revoked because nearly all disbursements benefited private individuals
The IRS revoked a nonprofit's tax-exempt status under IRC Section 501(c)(3). The organization was set up to run a program letting people designate contributions to pre-qualified charities, and during …
IRS revokes 501(c)(3) status of an alumni support group that failed the supporting-organization responsiveness test
A charity can avoid being treated as a private foundation by qualifying as a "supporting organization" under IRC § 509(a)(3), but only if it has the right relationship with the public charity it suppo…
IRS revokes 501(c)(3) status of an advocacy group that stopped responding to the audit
To keep tax exemption under IRC § 501(c)(3), an organization must show it actually operates for charitable or educational purposes, and it must keep records and answer the IRS when audited. This organ…
IRS revokes 501(c)(7) status of a club funded almost entirely by investment income
A social club exempt under IRC § 501(c)(7) must be a real club: members who commingle for social and recreational purposes, supported mainly by dues, with no more than 35% of gross receipts coming fro…
IRS revokes 501(c)(7) status of a social club whose outside-membership income exceeded the 35% limit
A social club exempt under IRC § 501(c)(7) may take in no more than 35% of its gross receipts from sources outside its membership, a category that includes investment income. This club, which was open…
IRS revokes 501(c)(3) status of a charity that sold its operations and existed only to wind down and pay its directors
To keep tax exemption as a charity under IRC § 501(c)(3), an organization must actually operate for charitable purposes; it fails the "operational test" if more than an insubstantial part of what it d…
IRS revokes 501(c)(7) status of a social club whose nonmember income exceeded the 15% limit year after year
A tax-exempt social club under IRC § 501(c)(7) can take in only a limited share of its money from outside its membership: no more than 35% of gross receipts from all outside sources, and within that, …
IRS revokes 501(c)(7) status of a social club that leased its facilities to for-profit operators and earned substantial nonmember income
A tax-exempt social club under IRC § 501(c)(7) is supposed to be run substantially for the pleasure and recreation of its members, funded mostly by member dues, with only limited money coming from out…
IRS revokes a 501(c)(3) collection/museum charity that could not be distinguished from the affiliated social club that controlled it
A nonprofit had been recognized as a 501(c)(3) public charity (a publicly supported organization under sections 170(b)(1)(A)(vi) and 509(a)(1)) to assemble, collect, and display a significant collecti…
IRS revokes a "flow-through charity" used as a vehicle in a promoter's abusive donated-LLC-interest charitable-giving tax scheme
A nonprofit obtained 501(c)(3) status using a short-form application (Form 1023-EZ) and then operated as a "flow-through" for donated limited liability company (LLC) interests. On audit, the IRS found…
IRS denies 501(c)(3) status to a fraternal lodge whose main purpose is its own ritual activities
A fraternal lodge applied for 501(c)(3) charity status using the short Form 1023-EZ, then had to answer follow-up questions. The IRS denied the application on both of the two tests every charity must …
IRS removes a social club from its group exemption for exceeding the 35% investment-income limit
A social club that housed and served a group of students had its 501(c)(7) exemption pulled after an IRS audit. The club was a subordinate under a parent organization's group ruling; one related entit…
IRS revokes 501(c)(3) status of a defunct, family-funded charity that failed both the organizational and operational tests
The IRS revoked the 501(c)(3) exemption of a small charity that had essentially gone dormant. On audit, the founder explained that the group had started as a way to do occasional charitable activities…
IRS revokes a charity's 501(c)(3) status after it failed to produce its records
The IRS revoked a charity's 501(c)(3) exemption because the organization did not cooperate with an examination. The agency picked the group for audit to confirm its documents and activities matched it…
IRS revokes 501(c)(7) status of an inactive fraternity clubhouse corporation with only investment income
A corporation that owned and ran a clubhouse for a college chapter's members had its 501(c)(7) social-club exemption revoked after an IRS audit. It had been a subordinate under a parent organization's…
IRS disqualifies a self-declared 501(c)(7) club whose members never meet or commingle
An organization had been treating itself as a tax-exempt social club under 501(c)(7) without ever getting a formal ruling from the IRS and without being covered by any group exemption. On audit, the I…
IRS revokes 501(c)(7) status of a social club left with no members and only investment income
A tax-exempt social club (a subordinate chapter under a parent group exemption) had its 501(c)(7) status revoked after an IRS audit. A 501(c)(7) club must be organized and operated substantially for t…
IRS denies 501(c)(6) business-league status to a referral-networking club
A membership group applied to be recognized as a tax-exempt business league under 501(c)(6). Its members meet weekly to swap sales leads and refer business to one another, and it caps membership at on…
IRS denies 501(c)(3) status to a group that runs an annual community automotive festival
An organization already recognized as a 501(c)(4) social-welfare group applied to be reclassified as a 501(c)(3) charity, which would let donors deduct their gifts. Its main activity is planning and r…
Final denial of 501(c)(3) exemption to a hobby-enthusiast archive operated for substantial social purposes
An organization built around a particular product or brand (referred to only as "Z," described as part of automotive history) applied for charitable tax-exempt status under section 501(c)(3). Its main…
A VEBA may expand its membership to all former employees without losing its tax exemption
A voluntary employees' beneficiary association (VEBA) is a tax-exempt group under section 501(c)(9) that pays life, sick, accident, or similar benefits to its employee-members. This VEBA, funded only …
IRS treats a large trust distribution to a public charity as an "unusual grant" that will not upset its public-support status
A publicly supported charity must normally show that a large share of its funding comes from broad public support rather than a few big donors. A single very large gift can distort that math and threa…
IRS denies 501(c)(3) status to a juice and smoothie bar as a commercial business
An organization applied for recognition as a tax-exempt charity under section 501(c)(3). Its stated purpose was to promote health through education and by selling affordable organic juices, smoothies,…
IRS denies 501(c)(4) social welfare exemption to a tax-preparation operation run like a for-profit business
An organization applied to be recognized as a tax-exempt social welfare group under section 501(c)(4). Its sole activity was tax preparation, along with related services like tax resolution, audits, a…
IRS denies 501(c)(3) status to a cemetery organization
An organization whose only purpose is to hold title to and preserve a cemetery applied to be recognized as a tax-exempt charity under § 501(c)(3), using the streamlined Form 1023-EZ. The IRS denied th…
IRS denies 501(c)(3) status to a group whose only activity is renting out a community center
An unincorporated association applied for § 501(c)(3) charity status using the streamlined Form 1023-EZ, stating it maintains a community center that residents can rent for meetings, parties, and gath…
IRS revokes a charity's 501(c)(3) status after it failed to produce records substantiating its exempt purpose
A § 501(c)(3) organization (which appears to run gaming, raffle, and meal fundraisers connected to youth sports) was selected for audit. The IRS made repeated attempts by mail and phone to obtain its …
IRS finds a self-declared social-welfare group does not qualify under 501(c)(4)
An organization incorporated in its state and began filing annual returns with the IRS without ever applying for exempt status. Because a § 501(c)(4) social welfare organization does not need a formal…
IRS revokes a charity's 501(c)(3) status after it went silent during an audit
The IRS selected a § 501(c)(3) charity for examination and repeatedly tried to reach it by mail and phone, but the organization never produced its records. The group appeared to have dissolved with th…
IRS revokes a social club's tax exemption for excessive non-member income
A tax-exempt social club (IRC § 501(c)(7)) owned a building with two halls it rented to both member and non-member groups. On audit, the IRS found the club's income from non-members exceeded the limit…
IRS denies 501(c)(6) business-league status to a common-area maintenance association for a development
An association was set up under a development's declaration of easements, covenants, conditions, and restrictions to own and maintain the common areas of one area (Area 4) of the development. Its memb…
IRS denies 501(c)(6) business-league status to a common-area maintenance association for a development
An association was set up under a development's declaration of easements, covenants, conditions, and restrictions to own and maintain the common areas of one area (Area 3) of the development. Its memb…
IRS denies 501(c)(6) business-league status to a common-area maintenance association for a development
An association was set up under a development's declaration of easements, covenants, conditions, and restrictions to own and maintain the common areas of one area (Area 2) of the development. Its memb…
IRS denies 501(c)(6) business-league status to a common-area maintenance association for a development
An association was set up under a development's declaration of easements, covenants, conditions, and restrictions to own and maintain the common areas of one area of the development. Its members are t…
IRS denies 501(c)(4) status to an ethnic mutual-aid society that pays members' funeral costs
A mutual-aid society formed by a group of friends of the same ethnic background, all immigrants from one country, applied to be recognized as a 501(c)(4) social welfare organization. Its main activity…
IRS denies 501(c)(3) status to a high school class fund set up to pay for reunions
A group formed by a high school graduating class's student government committee applied for 501(c)(3) status using the short Form 1023-EZ, claiming an educational purpose. During high school the class…
IRS denies 501(c)(12) status to a statewide insurance risk-sharing pool for water companies
An unincorporated association whose members are mutual water companies in one state applied to be recognized as tax-exempt under section 501(c)(12). That section exempts benevolent life insurance asso…
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.