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 field hockey charity for member-account fundraising
The IRS revoked the tax exemption of an organization formed to teach field hockey to high-school-aged girls and help players pursue collegiate opportunities. The organization assigned fundraising proc…
IRS revokes a social club's tax exemption for excess non-member and investment income
This is a final IRS determination revoking an organization's tax-exempt status as a social club under Section 501(c)(7). Section 501(c)(7) exempts clubs organized for pleasure and recreation that are …
IRS revokes a social club's exemption after recurring non-member rental income
The IRS revoked an organization's tax-exempt status as a social club under Section 501(c)(7). The organization rented its hall and an apartment to the public, and its non-member income exceeded the li…
IRS revokes a social club's exemption because recurring public rentals dominated its income
The IRS concluded that an organization no longer qualified as a tax-exempt social club under Section 501(c)(7). The organization combined a member society with historical education, scholarships, char…
IRS revokes a social club whose income came entirely from rentals and investments
The IRS revoked an organization's tax-exempt status as a social club under Section 501(c)(7). The organization held an annual alumni reunion and several meetings, but it owned a lodge and parking lot …
IRS revokes a charity that failed to file its return or provide examination records
The IRS revoked an organization's tax-exempt status under Section 501(c)(3). The organization did not file its required annual Form 990 for the year under examination and did not provide the requested…
IRS retroactively revokes a charity whose articles failed the organizational test
The IRS revoked an organization's Section 501(c)(3) status back to its original exemption date. On Form 1023-EZ, the organization had attested that its organizing document limited its purposes to exem…
IRS revokes a charity that did not provide complete audit records
The IRS revoked an organization's Section 501(c)(3) status because it could not verify the organization's documents, activities, or operations. The organization had obtained exemption through Form 102…
IRS revokes a youth hockey charity dominated by social and recreational events
The IRS revoked the Section 501(c)(3) status of an organization formed to provide hockey equipment, education, and scholarships to young athletes. During the year examined, the organization collected …
IRS denies business-league status to a plaza owners association
The IRS denied Section 501(c)(6) exemption to an association of property owners in a commercial plaza. Membership arose automatically from owning a parcel, without regard to the owner's particular tra…
IRS revokes a charity after repeated promises to provide records went unfulfilled
The IRS revoked an organization's Section 501(c)(3) status because it did not provide records needed to examine its activities, receipts, and expenditures. The organization had obtained exemption thro…
IRS revokes a suspended charity that did not respond to its audit
The IRS revoked an organization's Section 501(c)(3) status after it failed to respond to an examination. The organization had obtained exemption through Form 1023-EZ, had not filed a Form 990-series r…
IRS revokes a purported museum that primarily sold products and benefited its founder
The IRS revoked the Section 501(c)(3) status of an organization that said it operated a museum. During a site visit, the IRS found no visible museum, public display, accessible entrance, or other acti…
IRS revokes a foster-child charity for personal spending and inadequate records
The IRS revoked the Section 501(c)(3) status of an organization formed to sponsor fitness opportunities for foster children. Bank records obtained by summons showed payments for clothing, groceries, a…
IRS disqualifies a social club whose oil-and-gas royalties dominated its income
The IRS disqualified a self-declared social club from exemption under Section 501(c)(7). The club provided recreation and firearms education to hunters and marksmen, but its primary income came from r…
IRS denies exemption to an association maintaining a road for its members
The IRS denied Section 501(c)(3) status to an association whose activity was maintaining a road used by its member property owners. The owners either performed the work or hired a contractor, and ever…
IRS revokes a religious school after missing records and alleged embezzlement
The IRS revoked the Section 501(c)(3) status of a religious elementary school that did not respond to seven information-document requests or substantiate its activities and expenditures. The report sa…
IRS revokes a charity that ignored its audit and produced no records
The IRS revoked an organization's Section 501(c)(3) status after it failed to respond to an audit or produce records supporting its exempt activities. The organization had received exemption through F…
IRS revokes an inactive animal shelter after eviction and state cancellation
The IRS revoked the Section 501(c)(3) status of an animal-rescue organization that had stopped operating. The organization’s president said the shelter had been evicted, its animals and most assets we…
IRS revokes an inactive supporting organization that never received funding
The IRS revoked the Section 501(c)(3) status of a Type I supporting organization that had never become operational. The organization was formed to make charitable distributions and grants to a specifi…
IRS revokes a military-member association for private benefit and defective documents
The IRS revoked the Section 501(c)(3) status of an unincorporated association formed to promote camaraderie among assigned military personnel. Member dues paid for plaques and other departure gifts, m…
IRS revokes an inactive supporting organization after its supported organization entered bankruptcy
The IRS revoked the Section 501(c)(3) status of an organization formed to raise funds for and support a hospital or related public facilities. Its supported organization entered bankruptcy, and the su…
IRS revokes a dormant fraternity’s social-club exemption because all receipts were investment income
The IRS revoked the Section 501(c)(7) exemption of a fraternity that had stopped conducting social activities after selling its house. During the two examined tax years, all of the organization’s rece…
IRS revokes a private foundation whose funds inured to its sole trustee
The IRS revoked the Section 501(c)(3) status of a private non-operating foundation created to support the arts and provide scholarships to musicians, composers, and lyricists. The foundation transferr…
IRS revokes a business league's exemption for promoting two product brands rather than a whole line of business
The IRS revoked an organization's IRC § 501(c)(6) exemption as a business league. The group was an association of independent distributors ("marketers") who were all affiliated by contract with a sing…
IRS disqualifies a self-declared social club whose income came almost entirely from nonmembers
This letter is a final determination that a self-declared social club does not qualify for tax exemption under IRC § 501(c)(7). The club owned its building, operated bars and rented its halls to the g…
IRS revokes a charity's exemption after it ignored records requests during an audit
The IRS issued a final determination revoking an organization's IRC § 501(c)(3) tax-exempt status after the organization repeatedly failed to respond to the examiner's requests for financial and organ…
IRS denies 501(c)(3) status to a group that gave airline tickets to fee-paying veterans
The IRS issued a final adverse determination denying tax-exempt status under IRC § 501(c)(3) to an applicant that planned to provide airline tickets to veterans and service members who paid an annual …
IRS revokes a social club's exemption for excess investment income from nonmember sources
The IRS revoked a social club's IRC § 501(c)(7) exemption after finding that substantially all of its income came from investments, a nonmember source, well over the 35% of gross receipts that social …
IRS determines a dormant fraternal cemetery-plot organization does not qualify for exemption
The released package for this organization mixes two sections of the Code, and the text below is reproduced as the IRS released it. The front final determination letter states that the organization do…
IRS revokes a 501(c)(3)'s exemption after the group could not be reached during an audit
The IRS revoked an organization's IRC § 501(c)(3) exemption after it failed to respond to repeated audit requests for information about its finances and activities. The group had obtained exemption th…
IRS revokes a social club's exemption for investment income over the 35% nonmember limit
The IRS revoked the IRC § 501(c)(7) exemption of a members' club after finding that its investment income (a nonmember source) exceeded, on a continuing basis, the 35% of gross receipts that social cl…
IRS revokes an inactive charity's exemption for failing the operational test
The IRS revoked an organization's IRC § 501(c)(3) exemption after finding it had not consistently operated and had shown no concrete plans or reasonable steps to begin operating, so it failed the oper…
IRS revokes a veterans-group auxiliary's exemption because its youth baseball players do not meet the membership rules
The IRS revoked the § 501(c)(19) exemption of an auxiliary unit included in a veterans organization's group ruling. The auxiliary's main activity was operating a community youth baseball team, and its…
IRS revokes a recycling charity's exemption after its activities shifted to managing and selling a landfill
The IRS revoked the § 501(c)(3) exemption of an organization originally formed to promote recycling and create employment for people with disabilities. The organization later acquired a closed landfil…
IRS revokes a dormant fraternity social club that had no members and lived on investment income
A local college fraternity chapter had been recognized as a tax-exempt social club under § 501(c)(7). The chapter folded, sold its fraternity house, and since then existed mainly to hold the mortgage …
IRS revokes a 501(c)(4) civic league that went inactive and stopped filing
A social-welfare organization recognized as exempt under § 501(c)(4) stopped operating and had not filed a Form 990 for multiple years. Its last return reported zero income, zero expenses, zero assets…
202050017: IRS denies 501(c)(3) status to a golf-collectors membership club
A membership organization of golf enthusiasts and memorabilia collectors, already recognized as a 501(c)(7) social club, applied to be reclassified as a 501(c)(3) charity so that donations to it would…
202050016: IRS denies 501(c)(6) business-league status to a standards-licensing consortium
A member-based organization that develops an open technical standard (for exchanging video and metadata formats) and licenses it to its members applied to be recognized as a tax-exempt "business leagu…
IRS denies § 501(c)(3) exemption to an amusement-ride and event-rental nonprofit as operated for substantial recreational and commercial purposes
To be tax-exempt under § 501(c)(3), an organization must be operated exclusively for charitable, educational, or similar purposes; a single substantial non-exempt purpose defeats exemption no matter h…
202047015: A garden-home HOA is denied 501(c)(4) social-welfare exemption because it serves its own lot owners, not the public
A homeowners association for a small garden-home subdivision applied to be recognized as a tax-exempt social welfare organization under Section 501(c)(4). Its money comes from member dues, and it spen…
202047014: A community-festival nonprofit is denied 501(c)(3) status because its social and recreational activities are too substantial
A nonprofit that organizes an annual community festival, and is already recognized as a 501(c)(4) social welfare group, applied to upgrade to charitable status under Section 501(c)(3). The festival fe…
202047013: A farmers' market nonprofit is denied 501(c)(3) status because it mainly benefits its paying vendors
A community farmers' market organization applied for charitable exemption under Section 501(c)(3) using the streamlined Form 1023-EZ. It runs a seasonal market where growers and vendors pay a fee for …
202047012: A business-networking club is denied 501(c)(3) status because it exists to promote its members' businesses
A business-networking group applied for charitable exemption under Section 501(c)(3) using Form 1023-EZ. Its members are business owners who meet weekly to exchange referrals and promote each other's …
202047011: A supporting-organization trust is reclassified as a private foundation for failing the Type II and Type III tests
An irrevocable charitable trust that is exempt under Section 501(c)(3) had been classified as a public charity, specifically a supporting organization under Section 509(a)(3), rather than a private fo…
202047010: A pop-up market organizer for small businesses is denied 501(c)(3) status as a commercial operation
An organization that produces large public events and markets for small-business vendors (makers, artists, chefs, and similar) applied for charitable exemption under Section 501(c)(3). The events are …
202047009: A construction plan-room membership service is denied 501(c)(3) status because it serves its members, not the public
An organization formed to take over a for-profit "plan room" (a facility where construction contractors review building plans and specifications to prepare bids) and convert it to a nonprofit applied …
IRS denies § 501(c)(3) status to a member health-cost sharing organization
An organization applied for § 501(c)(3) recognition after changing its stated purpose from helping underserved businesses to operating a health-cost sharing program. Members would sign a statement of …
IRS denies charitable status to an artists' cooperative gallery
A membership cooperative of local artists applied for 501(c)(3) charitable status using the short Form 1023-EZ. It runs a gallery where members pay an initial fee and monthly dues to display and sell …
IRS denies exemption where a proposed charity would develop a pistachio farm for an insider-owned business
An organization sought § 501(c)(3) status as a Type I supporting organization for a charity serving youth and families affected by human trafficking. Its main financial plan was to use a large grant f…
IRS denies exemption to an investment adviser managing impact funds
A nonprofit investment adviser proposed to organize and manage private funds that financed social-service, affordable-housing, and clean-energy projects. It planned to raise capital from impact invest…
IRS denies exemption for an insufficiently documented greenspace project
A nonprofit proposed to plan, develop, and operate a public greenspace above a transportation corridor in a densely populated urban area. The project was intended to add recreational space, connect su…
IRS denies exemption because a related business received substantial private benefit
A nonprofit planned to mentor and support males through online and individual mentoring, after-school programs, school and church partnerships, sports, and community service. It used a character and e…
IRS denies social-welfare exemption to a private condominium association
A condominium association sought recognition as a tax-exempt social-welfare organization under IRC § 501(c)(4). It maintained the development's common areas and building exteriors, collected assessmen…
IRS denies charitable status for a fund paying bonuses to retirement-community staff
Residents of a retirement community formed an organization to collect gifts and distribute year-end bonuses to the community's support staff. Every support worker received a bonus, with no application…
IRS treats a large alumnus gift to a fraternity-linked charity as an "unusual grant" that won't sink its public-support status
A publicly supported charity has to keep getting enough small, broad-based donations to pass the "public support" test; one huge gift can distort that math and jeopardize its status. The tax rules let…
IRS denies 501(c)(3) status to a group that leases advertising vehicles to disabled individuals, finding it runs a commercial business
An organization applied to be recognized as a tax-exempt charity under § 501(c)(3), saying its purpose was to help disabled people earn a living. Its actual plan was to lease outdoor advertising units…
An exempt society's online job-board income is taxable business income, not a tax-free royalty
A tax-exempt professional and academic society (a 501(c)(3) public charity) runs an online job board that connects employers with job seekers for a fee, using an outside for-profit vendor to host and …
IRS rules a VEBA may offer members whole life insurance as a permissible "life benefit"
A voluntary employees' beneficiary association (VEBA) is a member-funded organization, tax-exempt under section 501(c)(9), that pays life, sick, accident, and similar benefits to its members. This VEB…
IRS denies exemption to a business networking group
An organization sought recognition as tax-exempt under § 501(c)(3). Its bylaws described a networking group for business owners associated with a particular nationality, and its activities included bu…
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.