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 denies § 501(c)(7) social-club status to a food buying club
A group that runs a food buying club applied to be recognized as a tax-exempt social club under Section 501(c)(7), and the IRS said no. Section 501(c)(7) is for clubs organized for pleasure and recrea…
IRS denies § 501(c)(6) business-league status to an angel-investor network
An invitation-only angel-investor network applied to be recognized as a tax-exempt business league under Section 501(c)(6), and the IRS said no. The group recruits accredited investors as members, scr…
IRS denies § 501(c)(3) status to a commercial design business
A one-person organization applied for recognition as a charity under Section 501(c)(3), and the IRS said no. Its main activity was creating designs for clients' homes for a per-client fee (based on th…
IRS denies § 501(c)(4) status to a group running an IRC 105-plan loan and "Social Security solvency" scheme
An organization applied to be recognized as a tax-exempt social welfare organization under Section 501(c)(4), and the IRS said no. The group had a two-part plan. First, it would lend money to employee…
IRS denies 501(c)(3) status to a soccer team's independent supporters' club
A membership group applied for tax-exempt charity status under 501(c)(3), describing itself as an independent supporters' group for a soccer team (referred to as C). Its activities center on the team:…
IRS denies 501(c)(3) status because the applicant never documented what it actually does
An organization applied for tax-exempt charity status under 501(c)(3) using the short Form 1023-EZ, describing its mission as serving "religious and funeral purposes." The Form 1023-EZ is mostly a set…
IRS denies 501(c)(7) social-club status to a corporation running a seasonal trailer park
A corporation applied for tax-exempt status as a 501(c)(7) social club. It owns and operates a seasonal trailer park in which each mobile-home site corresponds to a share of the company's stock, so on…
IRS denies 501(c)(6) business-league status to a single-vendor customer user group
An organization applied to be recognized as a tax-exempt "business league" under 501(c)(6). It operates as the customer and user community for the products of one for-profit technology company (referr…
IRS denies 501(c)(3) status to a health care sharing ministry that operates like a commercial insurance business
A startup applied for recognition as a tax-exempt charity under 501(c)(3) so it could run a "health care sharing ministry," a program where members pay a monthly "share" into a common resource that he…
Accountable care organization denied Section 501(c)(4) status
An accountable care organization owned by a Section 501(c)(3) health system asked to be recognized as a Section 501(c)(4) social-welfare organization. It coordinated patient care under the federal Med…
IRS denies 501(c)(3) status to a cannabis-sacrament church because its worship uses a federally illegal drug
A group applied to be recognized as a tax-exempt church under 501(c)(3). Its stated purpose is to advance a religion whose worship treats consecrated cannabis as a sacrament, comparable to how the Rom…
IRS denies 501(c)(3) status to a fund that gives college scholarships to all children of a cooperative's employees, with no need or merit test
An organization applied to be recognized as a tax-exempt charity under section 501(c)(3). Its only activity was giving college scholarships to the children of employees of a particular cooperative, in…
Late relief to revoke a 501(h) lobbying election, effective retroactively
A public charity had earlier filed Form 5768 to make a section 501(h) election, which swaps the vague "no substantial part" limit on lobbying for a dollar-based expenditure test. It later decided the …
Final adverse determination denying 501(c)(3) exemption to an off-highway-vehicle recreation club
An off-highway-vehicle (OHV) club applied for recognition as a tax-exempt charity under § 501(c)(3), using the streamlined Form 1023-EZ. The IRS denied it. To qualify, an organization must pass both a…
Final adverse determination denying 501(c)(3) exemption to a shopping-center merchants' association
A membership group made up of the businesses in a shopping-center area applied for recognition as a tax-exempt charity under § 501(c)(3), using the streamlined Form 1023-EZ. The IRS denied it. To qual…
Final adverse determination revoking a 501(c)(7) social club's exemption for excessive nonmember income
A fraternal and social membership club had been treating itself as tax-exempt under § 501(c)(7) as a self-declared exempt organization (it never filed Form 1024). On audit the IRS found the club drew …
Final adverse determination denying 501(c)(3) exemption to an open-source wireless-network organization
An organization applied for recognition as a tax-exempt charity under § 501(c)(3), and the IRS denied it. The group was formed to develop and promote open-source software for a decentralized wireless …
Final adverse determination denying 501(c)(3) exemption to a university alumni social and networking club
A local alumni group affiliated with a university applied for tax-exempt charity status under § 501(c)(3) using the streamlined Form 1023-EZ, and the IRS denied it. The group's stated mission was to e…
Final adverse determination denying 501(c)(3) exemption to a community recreational sports club
A community sports club applied for tax-exempt charity status under § 501(c)(3) using the streamlined Form 1023-EZ, and the IRS denied it. The club fielded youth and adult teams, ran leagues and tourn…
Final adverse determination revoking a social club's 501(c)(7) exemption for too much non-member income
A tax-exempt social and recreation club described in § 501(c)(7) had its exemption revoked because too much of its income came from outside its membership. Social clubs are exempt only if they are sup…
Final adverse determination revoking a charity's 501(c)(3) exemption for not responding to an audit
A charity recognized under § 501(c)(3), which had described itself as running a summer camp program for abused, neglected, and abandoned teens, lost its tax-exempt status because it did not cooperate …
Final adverse determination revoking a 501(c)(3) exemption for an unanswered audit and a missing dissolution clause
A small charity that had obtained § 501(c)(3) status through the streamlined Form 1023-EZ application lost that status after an examination. The IRS sent a long series of letters and made repeated pho…
Final adverse determination revoking a 501(c)(3) charity's exemption for failing to substantiate that its emergency-relief spending served exempt purposes
A small charity that had obtained § 501(c)(3) status through the streamlined Form 1023-EZ application lost that status after an examination. The organization said its purpose was emergency assistance …
Final adverse determination revoking a 501(c)(3) supporting organization's exemption because it never became operational
A nonprofit that had been recognized as a § 501(c)(3) organization, and classified as a Type I supporting organization under § 509(a)(3), lost its exemption because it never actually operated. The org…
Final adverse determination revoking a 501(c)(3) exemption, back to its start, for a members-only military social organization that failed both the organizational and operational tests
An organization that had obtained § 501(c)(3) status through the streamlined Form 1023-EZ application lost that status, and lost it retroactively to the day the exemption began. In substance the group…
Final adverse determination revoking a 501(c)(3) exemption, back to its start, because the organizing document failed the organizational test
A nonprofit that had obtained § 501(c)(3) status through the streamlined Form 1023-EZ application lost that status retroactively to the day it began. On its Form 1023-EZ the organization had attested …
Final adverse determination revoking a Type III supporting organization's 501(c)(3) exemption for becoming inactive after its supported organization went bankrupt
A charity that had been recognized as a § 501(c)(3) organization and classified as a Type III (non-functionally integrated) supporting organization under § 509(a)(3) lost its exemption after it stoppe…
Final adverse determination revoking a private foundation's 501(c)(3) exemption for private inurement to its sole trustee
A private non-operating foundation, created under a person's will to support the arts and provide scholarships to musicians, composers, and lyricists, lost its § 501(c)(3) exemption for private inurem…
Final adverse determination revoking a 501(c)(4) civic league's exemption after it stopped operating
A social welfare organization exempt under § 501(c)(4), organized as a local post with officers such as a Commander and an Alternate Treasurer and affiliated with a state and national parent under a g…
202150034: IRS revokes a veterans charity's 501(c)(3) status for inurement, finding its two officers skimmed solicited cash to fund gambling
A small charity said it helped veterans by running sober-living rooming houses and giving out basic necessities, funded by "bucket" cash solicitations outside retail stores. On audit, the IRS conclude…
202150033: IRS revokes a ministry's 501(c)(3) status for inurement after its president used the organization's account for personal spending
A one-person ministry doing life coaching, mentoring, Bible study, and athletic coaching lost its tax-exempt charity status. The organization's founder and president had sole control of its single che…
202150032: IRS revokes a fraternity house corporation's 501(c)(7) social club status because all of its income came from rent and investments, not members
A tax-exempt social club under Internal Revenue Code § 501(c)(7) is meant to be a members' club for pleasure and recreation, supported mainly by member dues, fees, and assessments. Federal law (P.L. 9…
202150031: IRS denies 501(c)(3) status to a family fund that covers funeral and emergency costs for the descendants of one ancestor
A membership fund applied to be recognized as a tax-exempt charity under Internal Revenue Code § 501(c)(3). Its members were the blood-related male descendants of a single ancestor, and the fund's pur…
202150030: IRS revokes a charity's 501(c)(3) status after it stopped filing returns and did not respond to the audit
A public charity recognized under Internal Revenue Code § 501(c)(3) lost its exemption for the simplest of reasons: it stopped filing its annual return and never responded to the IRS. Every exempt org…
202150029: IRS revokes a charity's 501(c)(3) status after it ignored the audit and never filed its returns
A small charity that had been recognized as tax-exempt under Internal Revenue Code § 501(c)(3) lost that status because it went silent. The organization had obtained exemption through the streamlined …
202150028: IRS revokes a homeowners' association's 501(c)(4) status for serving its members, not the community, and for ignoring the audit
A homeowners' association that had ended up treated as a tax-exempt "social welfare" organization under Internal Revenue Code § 501(c)(4) lost that status for two independent reasons. First, it never …
202150027: IRS revokes a defunct diagnostic charity's 501(c)(3) status for failing both the organizational and operational tests and not producing records
A charity originally recognized under Internal Revenue Code § 501(c)(3) to run a diagnostic center for people with developmental disabilities lost its exemption after it effectively stopped operating.…
202150026: IRS revokes a cemetery association's 501(c)(3) status because running a cemetery is not a charitable purpose
A cemetery association that had obtained recognition as a charity under Internal Revenue Code § 501(c)(3) through the streamlined Form 1023-EZ lost that status on audit, because operating a cemetery i…
202150025: IRS revokes a terminated charity's 501(c)(3) status after it stopped responding and never filed its final return
A charity recognized under Internal Revenue Code § 501(c)(3) told the IRS it had terminated, but then never wrapped things up on paper, so the IRS revoked its exemption. During the examination the rev…
202150024: IRS disqualifies a hunting club's 501(c)(7) status because oil and gas royalties, not membership, drive its income
A social club, a hunting and shooting club that also does firearm-safety education and land conservation, had never gotten an IRS determination letter but had filed for years as a self-declared tax-ex…
202150023: IRS revokes a social club's 501(c)(7) status for recurring nonmember income from renting apartments above its clubhouse
A social club recognized as tax-exempt under Internal Revenue Code § 501(c)(7) lost that status because too much of its money came from outside its membership. A § 501(c)(7) club must be operated subs…
202150022: IRS revokes a defunct fraternity chapter's 501(c)(7) status: no members for a decade, income only from investments
A local chapter of a national fraternity that had been recognized as a tax-exempt social club under Internal Revenue Code § 501(c)(7) lost that status because it no longer functioned as a club at all.…
202150021: IRS revokes a charity's 501(c)(3) status after it never produced records for the audit despite months of attempted contact
A public charity recognized under Internal Revenue Code § 501(c)(3) through the streamlined Form 1023-EZ lost its exemption because the IRS could never complete an examination of it. Over many months …
202150020: IRS denies 501(c)(3) status to an ethnic community mutual-aid group that mainly pays benefits to its own members
A mutual-aid association organized around an ethnic community applied for recognition as a tax-exempt charity under Internal Revenue Code § 501(c)(3), and the IRS denied it because the group mainly se…
202150019: IRS revokes a motorcycle festival charity's 501(c)(3) status for operating primarily for private benefit
A charity had been recognized under Internal Revenue Code § 501(c)(3), stating in its exemption application that it would hold convention-style motorcycle rallies to raise money for other IRS-approved…
202150018: IRS revokes an inactive charity's 501(c)(3) status for failing to produce records
A small charity had been recognized as tax-exempt under Internal Revenue Code § 501(c)(3) after filing the streamlined Form 1023-EZ application. When the IRS selected it for audit, the organization co…
IRS revokes a charity's 501(c)(3) status for failing to produce records for an audit
A small organization recognized as a 501(c)(3) charity was selected for audit and then went silent. The IRS repeatedly mailed and called, but the group never produced the records needed to show it was…
IRS revokes a hospital's 501(c)(3) status after it sold its assets and stopped operating
A tax-exempt hospital sold all of its assets and stopped providing hospital services under its own name. After the sale, the corporate entity conducted no activities at all. It never filed articles of…
IRS revokes a private foundation's 501(c)(3) status for never operating and serving private interests
A private foundation set up to fund small businesses and charities never actually did any charitable work. Houses tied to the founder's family were put in the foundation's name but kept running under …
IRS revokes a housing charity's 501(c)(3) status for private inurement and failure to produce records
An organization formed to house and train homeless, needy, and disabled people lost its 501(c)(3) exemption after an audit uncovered signs that its founders were using it for private benefit. Bank rec…
IRS revokes a squadron morale club's 501(c)(3) status for non-exempt social purpose and failure to produce records
An organization set up to improve the health, welfare, and morale of members of a specified military work unit lost its 501(c)(3) exemption. Its main activities were social and recreational, such as h…
IRS revokes a supporting organization's 501(c)(3) status where it had no assets or activities
An organization had been recognized as a 509(a)(3) supporting organization, a type of public charity that exists to support another specified charity. On audit, it turned out the organization had no i…
IRS revokes a girls' field hockey booster club's 501(c)(3) status for funneling fundraising to member families
A club formed to teach high-school-aged girls field hockey and field a travel team lost its 501(c)(3) exemption after an audit examined how it handled fundraising money. The club kept a separate accou…
IRS revokes a charity's 501(c)(3) status for failing the organizational test on a Form 1023-EZ
This organization got its 501(c)(3) status through the short-form application, Form 1023-EZ, on which it attested that its organizing documents met the legal requirements. On audit, the IRS found that…
IRS revokes a 501(c)(3) that stopped responding to its audit and never produced records
An organization that had been recognized as a 501(c)(3) charity through the streamlined Form 1023-EZ application was selected for audit to confirm its actual activities matched its approved exempt pur…
IRS revokes an animal-sanctuary foundation's 501(c)(3) status after it became unreachable for audit
A foundation set up as a vegan animal sanctuary and education center, providing permanent sanctuary to animals (with a stated specialty in horses) and experiential education about human-animal relatio…
IRS revokes a historic-preservation foundation's 501(c)(3) status as an instrument of a related private social club
A foundation had been recognized as a 501(c)(3) public charity to preserve the history and architecture of a downtown area, with particular focus on one historic building. On audit the IRS found it wa…
IRS denies 501(c)(6) business-league exemption to a members-only referral and networking group
An organization applied to be recognized as a tax-exempt business league under section 501(c)(6). It ran as a closed referral and networking group: membership was capped at one business per line of tr…
IRS revokes a church's exemption for private benefit and a circular flow of tithes back to its members
An organization recognized as a 501(c)(3) church was examined under the special church-audit rules of Internal Revenue Code section 7611, and the IRS revoked its exemption on three grounds. First, it …
IRS revokes a doctor-run free-clinic charity for private inurement and unaccounted cash flowing to its founder
An organization had been recognized as a 501(c)(3) public charity to provide free medical care to homeless and underprivileged people. It was founded and controlled by a single physician, who was its …
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.