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 youth baseball team's veterans-auxiliary exemption because its members are minor athletes, not war veterans
A community youth baseball team had been recognized as tax-exempt as an auxiliary unit under a local veterans post's group exemption, which rests on Internal Revenue Code section 501(c)(19) (posts and…
IRS revokes a recycling charity's exemption after it abandoned recycling to manage a bankrupt landfill
An organization was recognized as a 501(c)(3) public charity (under section 509(a)(2)) to run recycling centers, teach the public about recycling, and give disabled people employable skills through re…
IRS denies 501(c)(3) exemption to an amateur-radio expedition group that serves its participants' hobby interests
An organization that runs amateur-radio expeditions (traveling to remote locations to set up radio stations and make as many contacts as possible with operators worldwide) applied for recognition as a…
IRS denies 501(c)(4) exemption to a commercial-development management association that benefits only its member owners
A management association for a commercial real estate development applied to be recognized as a tax-exempt social welfare organization under section 501(c)(4). The association is a mutual benefit corp…
IRS denies 501(c)(3) to a group that funnels fee-paying members into its president's for-profit crypto-mining business
An organization applied for recognition as a 501(c)(3) charity, describing itself as a community-outreach and learning project whose mission was to provide homes for the less fortunate and eradicate h…
IRS denies 501(c)(3) to a dental-therapist professional association that serves its members' industry interests
A professional association for dental therapists applied for recognition as a 501(c)(3) charity. It was the successor to a 501(c)(6) business-league organization whose exemption had been automatically…
A large one-time grant counts as an "unusual grant," so it won't cost a public charity its publicly-supported status
A public charity that is classified as a section 509(a)(2) organization was offered a cash grant far larger than the donations it normally receives, in an amount that dwarfed its annual budget. That c…
IRS denies 501(c)(3) exemption to an adult men's softball team operated mainly for its members' recreation
A group that fields an adult men's softball team applied for 501(c)(3) charitable status using the short Form 1023-EZ, and the IRS denied it. The team holds weekly practices and monthly local tourname…
IRS denies 501(c)(3) exemption to a group whose only activity is maintaining a family cemetery
An organization applied for tax-exempt charitable status under section 501(c)(3), and the IRS turned it down. The group's sole activity is preserving and maintaining a family cemetery: members of one …
IRS denies 501(c)(3) exemption to a trust formed to fund a film based on its founder's copyrighted screenplay
An individual set up a trust, named himself its sole trustee and donor, and on the same day licensed the trust the rights to a film screenplay he had written and copyrighted. The trust's plan was to r…
Professional networking group denied Section 501(c)(3) status
A membership organization sought recognition as a Section 501(c)(3) charity for activities that included professional networking events, promoting other nonprofits, and connecting professionals with v…
International travel-tour organization denied Section 501(c)(3) status
An organization sought Section 501(c)(3) status for international travel tours intended to advance a set of global sustainability goals and connect travelers with local nonprofit organizations. The to…
Habilitation program denied exemption for political activity and private benefit
An organization sought Section 501(c)(3) status for programs intended to improve health, wealth, and happiness, including a home for poor and distressed people. Residents of the home would be recruite…
Member bereavement fund denied Section 501(c)(3) status
A membership organization sought Section 501(c)(3) status for a bereavement fund. Members paid an enrollment fee and later contributions, and benefits were paid when a member or one of up to five name…
Off-road motorcycle club denied Section 501(c)(3) status
An off-road motorcycle club sought recognition as a Section 501(c)(3) organization. Its principal activities were two annual motorcycle competitions for adults and youth, along with a post-season awar…
Tourism trade association denied Section 501(c)(3) exemption
A trade association promoting tourism to and within a country applied for recognition as a Section 501(c)(3) charity. Its members included governments, tourism agencies, airlines, hotels, cruise lines…
Vintage racing club denied Section 501(c)(3) exemption
A vintage racing car club applied for recognition as a Section 501(c)(3) organization and said it fostered amateur sports competition. The club organized races for members, set vehicle construction an…
LGBTQ social and recreational group denied Section 501(c)(3) exemption
An organization sought Section 501(c)(3) status for activities serving adult LGBTQ participants around a redacted activity. It held networking, safety education, fundraising, pride, and other events, …
DMT sacrament organization denied exemption and church status
An organization sought Section 501(c)(3) exemption and church classification for a spiritual community whose primary activity was conducting paid weekend ceremonies using a redacted plant sacrament co…
Food and beverage industry service network denied Section 501(c)(3) exemption
A limited liability company sought Section 501(c)(3) exemption after operating for several years with a profit-making purpose and attempting, without evidence of a state filing, to convert to another …
Horse-show association denied Section 501(c)(3) exemption
An association organized competitions for a particular horse breed, including its main annual reining event, and funded itself through memberships, donations, sponsorships, advertising, and entry fees…
Neighborhood security group denied Section 501(c)(4) status
A mutual benefit corporation sought recognition as a tax-exempt social welfare organization under Section 501(c)(4). It collected voluntary donations from homeowners in one subdivision and hired a pri…
Industry networking group denied Section 501(c)(3) status
An industry group sought recognition as a charitable and educational organization under Section 501(c)(3). Its activities included industry luncheons, a fundraising golf tournament for scholarships, a…
IRS revokes an educational charity's exemption because its water-sports rental business served commercial and private interests
The IRS revoked a nonprofit's Section 501(c)(3) exemption after concluding that its primary activity was renting water-sports equipment in a commercial manner. The organization showed renters a brief …
Meeting-space organization denied fraternal exemption because it lacked a lodge system and fraternal activities
An organization formed to support a local recovery community applied for exemption as a domestic fraternal society under Section 501(c)(10). It provided rent-free meeting space, paid utilities and pro…
Charity's sale and restricted grant of subsidiary stock avoid UBTI and excess-benefit treatment
A public charity proposed separating one charitable program into a newly formed nonprofit organization that it controlled as sole member. It would transfer program assets and stock of a wholly owned f…
IRS denies exemption to a tourism group promoting local businesses
An organization sought Section 501(c)(3) status for activities intended to attract visitors to a geographic area through brochures, social media, marketing campaigns, events, signage, business assista…
IRS denies exemption to a farmers market serving vendors' private interests
An organization operated a weekly farmers market, charged seasonal and daily vendor fees, promoted participating vendors, and offered discounted fees to veteran farmers. It also described future educa…
IRS denies exemption to a family-controlled golf training organization
An organization formed by a founder and the founder's family proposed a golf training, recreation, entertainment, and business-development complex. It planned to charge standard industry fees, offer i…
IRS denies exemption to a group-purchasing and wellness trust
A trust was formed to receive health-insurance rebates, stabilize group health-plan premiums, fund wellness incentives, administer wellness programs, and procure products and services through group-pu…
IRS denies social-welfare exemption to a condominium association
A condominium association maintained and controlled common property for unit owners, whose membership was automatic and tied to ownership. The building was fenced against public access, and the associ…
IRS denies exemption to freemium research-software organization
An organization developed and distributed a web-based research-management platform under a freemium model, with professional users paying for expanded storage, projects, participants, security, suppor…
IRS denies exemption to open-source cryptocurrency software project
An organization proposed to develop, maintain, and distribute free open-source software for digital currency, support volunteer developers, operate a free digital library, work with schools, and spons…
IRS denies exemption for community rodeo organization
An organization already exempt under Section 501(c)(4) sought recognition under Section 501(c)(3). Its primary activity was planning, funding, and conducting a community rodeo, with most revenue comin…
IRS denies exemption to gated RV tailgating park
A member-owned recreational-vehicle park used primarily for tailgating sought exemption as a social-welfare organization under Section 501(c)(4). Members paid assessments to maintain fenced common are…
IRS revokes exemption for a tuition-fundraising organization
The IRS revoked a charity's Section 501(c)(3) status after finding that its concession-stand fundraising primarily benefited participating families. Members worked at concession stands, accumulated sh…
IRS denies Section 501(c)(3) status to an anime convention
An organization already exempt under Section 501(c)(4) applied for recognition under Section 501(c)(3). Its main activity was an annual anime and pop-culture convention featuring panels and cultural t…
IRS treats an animal-care bequest as an unusual grant
A publicly supported animal-welfare charity was named as a trust beneficiary for annual grants supporting medical care and adoption of uncared-for animals. Litigation delayed the payments, leaving a s…
IRS denies social-welfare status to a member death-benefit group
A membership organization collected registration fees, annual dues, and monthly funeral contributions to pay death benefits to members' beneficiaries. Membership depended on age, health, an applicatio…
IRS denies exemption to a health-research and software organization
A nonprofit organization developed health-care software, conducted research projects for pharmaceutical companies, and created educational content. Its formation document did not limit its purposes to…
IRS denies business-league status to a commercial property owners association
An association of commercial property owners maintained common areas, handled architectural controls, and assessed members for property taxes, insurance, lawn care, debris removal, drainage facilities…
IRS denies exemption to a private-road maintenance association
A property owners association collected money from its members to repair and maintain private roads serving their homes. Its organizing document stated a private-road purpose, and state law allowed it…
IRS denies exemption to a member-oriented equine events club
An equine membership organization operated a barn, arena, bleachers, and concession stand and gave members free facility use, event admission, voting rights, horse boarding, and access to amateur even…
IRS denies exemption to a fee-based laboratory testing service
An organization proposed providing laboratory collection and rapid-testing services to patients referred by health-care providers and to walk-in customers. It expected service fees to be its initial s…
VEBA student loan service is nonqualifying but de minimis
A voluntary employees' beneficiary association proposed offering members an online service that helps with student loan repayment and forgiveness programs. The trust asked the IRS to treat the service…
Class reunion fund denied Section 501(c)(3) exemption
An unincorporated association applied for Section 501(c)(3) exemption using Form 1023-EZ. Its only activity was holding money contributed by classmates who wanted to attend future class reunions. The …
Member funeral benefit organization denied exemption
A membership organization applied for Section 501(c)(3) exemption and private foundation status. It collected registration fees and monthly dues, then used its funds primarily to pay funeral and body-…
Private road association denied social club exemption
A mutual benefit corporation for neighborhood residents applied for social club exemption under Section 501(c)(7). Membership was mandatory for residents, and annual assessments paid for a private pav…
Small homeowners association denied social welfare exemption
A homeowners association for a small subdivision applied for social welfare exemption under Section 501(c)(4). It collected only HOA fees and maintained roads, a dry hydrant, entry features, signs, la…
Dog training club denied Section 501(c)(3) exemption
A dog club applied for Section 501(c)(3) exemption. Its articles promoted purebred dogs, dog training, obedience trials, and sanctioned matches. The club offered training classes to members and the pu…
IRS revokes a shooting club's exemption for public use and excess nonmember income
A Section 501(c)(7) social club operated indoor and outdoor shooting ranges and allowed the general public to use the outdoor range. A roadside sign and the club's website advertised that range as ope…
IRS denies Section 501(c)(3) status to an adjunct faculty mutual benefit group
An organization formed as a mutual benefit corporation applied for recognition as a Section 501(c)(3) charity. It promoted the professional treatment, economic welfare, and rights of adjunct faculty t…
IRS denies Section 501(c)(3) status to a member golf course
An organization operating a golf course and clubhouse for members applied for recognition as a Section 501(c)(3) charity. Members and their families could use the course and reserve the clubhouse, whi…
IRS denies social welfare exemption for political campaign activity
An organization sought exemption as a social welfare organization under Section 501(c)(4). Its activities included advertisements opposing a political candidate, highlighting elected officials and can…
Foreign regranting program qualifies under private-foundation rules
A private foundation planned to fund three foreign charities that would independently select local organizations for projects serving disadvantaged elders, children, teenagers, and other individuals. …
IRS denies exemption for funding founder-owned therapy provider
An organization proposed to pay for therapy when patients' insurance did not cover treatment. The only provider of that therapy in the state was a for-profit company solely owned by the organization's…
IRS denies exemption for insufficiently documented downtown program
An organization raised funds to revitalize a city's central business district and made grants to landlords and businesses within that district. It also ran annual community events and made grants to t…
IRS denies exemption for funding founder's education
An organization planned eventually to provide free health and wellness education and counseling, but its initial and primary activity was funding its founder's full-time professional education. It pai…
Cultural organization denied Section 501(c)(3) exemption
An organization applied for recognition as a Section 501(c)(3) charity to support a particular cultural community. Its stated activities included cultural exchange, traditions, language classes, works…
Business-referral group denied Section 501(c)(6) exemption
A membership organization applied for exemption as a business league under Section 501(c)(6). Its members represented different types of businesses, met regularly to exchange referrals, tracked the re…
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.