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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Church integrated auxiliary is not required to file Form 990
Most tax-exempt organizations must file an annual Form 990 information return, but there are exceptions. One exception covers an "integrated auxiliary of a church," a church-affiliated organization th…
Church integrated auxiliary is not required to file Form 990
Most tax-exempt organizations must file an annual Form 990 information return, but there are exceptions. One exception covers an "integrated auxiliary of a church," a church-affiliated organization th…
Church integrated auxiliary is not required to file Form 990
Most tax-exempt organizations must file an annual Form 990 information return, but there are exceptions. One exception covers an "integrated auxiliary of a church," a church-affiliated organization th…
Hunting retriever dog club denied 501(c)(3) exemption as a recreational group
A hunting retriever dog club applied for 501(c)(3) charity status using the short Form 1023-EZ, and the IRS turned it down. The club holds training days a few times a year and one or two hunting tests…
Nonprofit record label denied 501(c)(3) exemption for commercial, private-benefit operations
A nonprofit that operates like a record label applied for 501(c)(3) charity status on Form 1023, saying its mission is to support musicians with fair, transparent recording contracts and to give the p…
Governmental affiliate excused from filing Form 990
A tax-exempt organization asked the IRS to be excused from filing Form 990, the annual information return. The IRS agreed. Under IRC § 6033(a)(3)(B), the IRS has discretion to relieve certain exempt o…
501(c)(3) exemption denied to a member bereavement-aid group
A membership group applied to be recognized as a tax-exempt charity under IRC § 501(c)(3), and the IRS said no. The group collects donations and membership fees, then pays that money out to its own me…
501(c)(3) exemption denied to a low-income residential-solar operator
An organization installs, owns, and operates rooftop solar systems on the homes of low-income households, then charges those households for the electricity (through power-purchase agreements or fixed …
Assisted-living nursing professional association denied 501(c)(3) status for serving members' private interests
A membership organization for nurses who work in assisted living applied to be recognized as a tax-exempt charity under IRC § 501(c)(3). It was already exempt as a business league under § 501(c)(6). T…
Home-heating-fuel buying group denied 501(c)(4) status for serving fee-paying members over the community
A nonprofit formed to negotiate lower home-heating-fuel prices (oil, kerosene, propane) for residents of certain counties applied to be recognized as a tax-exempt social welfare organization under IRC…
Community political-advocacy group denied 501(c)(6) status for lacking a common business interest
An unincorporated association formed to raise the political influence of a particular community applied to be recognized as a tax-exempt business league under IRC § 501(c)(6). Members joined by referr…
Charter-fishing trade association denied 501(c)(3) status for serving members' private business interests
A professional trade association of charter fishing boat operators applied to be recognized as a tax-exempt charity under IRC § 501(c)(3), using the streamlined Form 1023-EZ. The IRS denied the applic…
Ethnic-business networking group denied 501(c)(3) status for promoting members' for-profit businesses
An organization that describes itself as promoting commerce, cultural exchange, and business integration for a particular ethnic community and for immigrant entrepreneurs applied to be recognized as a…
501(c)(3) denied to a religious-media ministry that resold its founder's for-profit products
An organization applied for 501(c)(3) status as a religious broadcasting and television ministry. Its founder and sole officer is an ordained pastor who also runs a for-profit media company that sells…
Governmental unit affiliate need not file Form 990
A tax-exempt organization asked the IRS to excuse it from filing Form 990, the annual information return most exempt organizations must submit. The IRS agreed. Under IRC § 6033(a)(3)(B), the IRS has d…
IRS denies 501(c)(3) status to a mixed-use real-estate redevelopment group that mostly leases commercial space and benefits a for-profit owned by its director
An organization applied to be recognized as a tax-exempt charity under IRC Section 501(c)(3), saying it would redevelop a former production facility in a poor neighborhood into a mixed-use building wi…
IRS denies 501(c)(4) social-welfare status to a homeowners' association with no areas open to the public
A homeowners' association for a residential subdivision applied to be recognized as a tax-exempt social welfare organization under IRC Section 501(c)(4). The IRS denied it, and because the association…
IRS excuses a governmental-unit affiliate from filing Form 990
Most tax-exempt organizations must file an annual information return (Form 990) with the IRS. This organization asked to be excused from that requirement. The IRS has discretion under IRC Section 6033…
IRS denies 501(c)(3) status to a homeowners'-association-style membership group
An organization that operates like a homeowners' association applied for 501(c)(3) charitable tax-exempt status using the streamlined Form 1023-EZ, and the IRS denied it. The group is a membership ass…
IRS denies 501(c)(6) business-league status to a business-referral networking group
A business-referral networking group (the kind where each member is the sole representative of their occupation and everyone is expected to pass leads to the others) applied for tax exemption as a 501…
IRS denies 501(c)(3) status to a commercial-style legal payment and practice-management platform
An organization that runs an online payment-processing and practice-management platform for lawyers (branded "D" in the redacted letter) applied for 501(c)(3) charitable status, pitching itself as a l…
IRS denies 501(c)(3) status to a short-term rental house run as a church "supporting organization"
A newly formed nonprofit that operates a single short-term rental house (a 4-bedroom farmhouse listed on a popular booking site) applied for 501(c)(3) status, and the IRS denied it. The organization w…
Early termination of a charitable lead annuity trust, paying the undiscounted remaining annuities to a donor-advised fund, triggers no foundation excise taxes
A charitable lead annuity trust (CLAT) pays a fixed amount to charity each year for a set term, and whatever is left at the end goes to a private beneficiary. This CLAT pays its annuity to a donor-adv…
Final adverse ruling denying 501(c)(3) exemption to an employee-aid fund that serves private, not public, interests
To be tax-exempt as a charity under section 501(c)(3), an organization must operate exclusively for public purposes, not to benefit a private group. Here, an unincorporated association applied for 501…
Final adverse ruling denying 501(c)(4) exemption to a gated homeowners association whose common areas are closed to the public
A social welfare organization can be tax-exempt under section 501(c)(4) only if it operates for the good of a whole community, not just its own members. Here, a real estate management association (whi…
Supporting organization's set-aside for a firefighting training facility approved
A tax-exempt, non-functionally integrated Type III supporting organization asked to count construction funds set aside for a firefighting training facility toward its annual distribution requirement. …
IRS denies 501(c)(3) exemption to a family heritage organization
A family heritage organization sought recognition as a tax-exempt charity under IRC Section 501(c)(3). Its activities included family reunions and picnics, genealogical and historical research, cemete…
Farmers market denied § 501(c)(3) exemption because it primarily benefited vendors
An organization sought § 501(c)(3) status for operating a farmers market where local producers and artisans paid weekly or seasonal fees to sell goods. It also held monthly educational events and host…
Business district group denied § 501(c)(6) exemption for providing member website services
A business district organization sought exemption as a business league or similar organization under § 501(c)(6). It promoted district events, ran sidewalk sales, and maintained a website where member…
Member-owned water company denied § 501(c)(3) exemption for serving private interests
A mutual benefit corporation sought § 501(c)(3) status for supplying and testing water from a shared well. It delivered water only to member-owned parcels, collected monthly member payments for usage …
IRS denies veterans organization exemption because too few members are war veterans
An organization supporting veterans, active-duty service members, and their families applied for exemption under IRC Section 501(c)(19). Its membership included current or former members of the Armed …
IRS denies 501(c)(3) exemption to a class reunion and scholarship group
An organization open only to graduates of one high school class applied for recognition as a charity under IRC Section 501(c)(3). It arranged reunions and other events for class members and raised mon…
IRS denies § 501(c)(3) exemption to a winter-sports social club that fails the organizational and operational tests
A newly formed ski and winter-sports club applied for recognition as a tax-exempt charity under Code section 501(c)(3), using the short Form 1023-EZ. The IRS denied the application and, after the club…
IRS denies § 501(c)(6) business-league exemption to a single-brand franchisee association
A group of franchisees who all own outlets of one particular brand formed an association and applied for tax exemption as a "business league" under Code section 501(c)(6). The IRS denied the applicati…
IRS denies § 501(c)(6) exemption to a commercial condominium owners' association
An owners' association for a commercial (business) condominium applied for tax exemption as a "business league" under Code section 501(c)(6). The association manages the building's common areas, handl…
IRS denies § 501(c)(3) exemption to a homeowners' association serving private member interests
A homeowners' association, organized as a mutual benefit common-interest development corporation, applied for charitable tax exemption under Code section 501(c)(3) using Form 1023-EZ. Its activities a…
IRS denies § 501(c)(3) exemption to an open-source software organization
An organization that develops and distributes open-source software (tools and patches for mobile apps) applied for recognition as a tax-exempt charity under IRC § 501(c)(3), using the short Form 1023-…
IRS revokes a private foundation's exemption for self-dealing loans to a founder's LLCs
The IRS revoked the tax-exempt status of a private foundation because it stopped operating for charitable purposes. On audit, the agency found the foundation's main activity was making loans to LLCs w…
501(c)(3) exemption denied to an off-road motorsport event organization
An organization applied for tax-exempt charitable status under Section 501(c)(3), but the IRS denied it. The group's sole activity was an annual off-road vehicle event: a multi-day gathering of enthus…
501(c)(3) exemption denied to a family-reunion and family-scholarship organization
An organization applied for charitable exemption under Section 501(c)(3), but the IRS denied it. The group was formed to plan and run reunions for one family, providing the location, transportation, m…
501(c)(3) exemption denied to an employee mutual-benefit association
An organization applied for charitable exemption under Section 501(c)(3), but the IRS denied it. The group is a mutual-benefit association open to full-time permanent employees of one employer who pay…
501(c)(3) exemption denied to a parade-participation organization
An organization applied for charitable exemption under Section 501(c)(3), but the IRS denied it on both required tests. Its articles of incorporation stated its purpose as "to enjoy the season of D" (…
501(c)(3) exemption denied to a college-athlete NIL collective
An organization applied for charitable exemption under Section 501(c)(3), but the IRS denied it. The group is a "name, image, and likeness" (NIL) collective tied to one school: it raises money to pay …
501(c)(7) social-club exemption denied to a homeowners association
An organization applied for tax-exempt status as a social club under Section 501(c)(7), but the IRS denied it. A 501(c)(7) club is exempt only if substantially all of its activities are for the pleasu…
501(c)(3) exemption denied to a cultural mutual-aid membership organization
An organization applied for charitable exemption under Section 501(c)(3), but the IRS denied it. The group is a cultural community organization whose members share a common cultural background. Its ma…
IRS excuses a governmental-unit affiliate from filing Form 990
An organization exempt under IRC Section 501(c)(3) asked the IRS to be relieved of the requirement to file the annual Form 990 information return. Section 6033(a)(3)(B) gives the IRS discretion to exc…
IRS denies 501(c)(7) social-club status to a homeowners association
A homeowners association for a single-family residential development applied to be recognized as a tax-exempt social club under IRC Section 501(c)(7). The IRS denied it. Section 501(c)(7) covers clubs…
IRS denies 501(c)(3) status to a counseling-subsidy charity that funnels funds to its directors' for-profit practice
A new nonprofit was formed to raise money and subsidize mental-health counseling for individuals, couples, and families who cannot afford full-cost care. The catch: its three directors own a for-profi…
IRS excuses a church's integrated auxiliary from filing Form 990
An organization exempt under IRC Section 501(c)(3) asked the IRS to be relieved of the requirement to file the annual Form 990 information return. Treasury Regulation Section 1.6033-2(g)(1)(i) provide…
IRS excuses a church-affiliated school from Form 990 (but Form 5578 still required)
A church-affiliated school exempt under IRC Section 501(c)(3) asked the IRS to be relieved of the requirement to file the annual Form 990. Treasury Regulation Section 1.6033-2(g)(1)(vi) provides that …
IRS excuses a foreign-focused mission society from filing Form 990
An organization exempt under IRC Section 501(c)(3) asked the IRS to be relieved of the requirement to file the annual Form 990. Treasury Regulation Section 1.6033-2(g)(1)(iv) provides that a mission s…
IRS denies 501(c)(4) social-welfare status to a neighborhood hall-rental association
A neighborhood association (membership is automatic for everyone living in its boundaries) applied to be recognized as a tax-exempt social-welfare organization under IRC Section 501(c)(4). The IRS den…
IRS denies 501(c)(8) fraternal status to a lodge dominated by public bingo
A fraternal organization that operates under the lodge system and pays death benefits to its members applied to be recognized as a tax-exempt fraternal beneficiary society under IRC Section 501(c)(8).…
IRS excuses a church's integrated auxiliary from filing Form 990
An organization exempt under IRC Section 501(c)(3) asked the IRS to be relieved of the requirement to file the annual Form 990 information return. Treasury Regulation Section 1.6033-2(g)(1)(i) provide…
IRS excuses a 501(c)(12) governmental-unit affiliate from filing Form 990
An organization exempt under IRC Section 501(c)(12) asked the IRS to be relieved of the requirement to file the annual Form 990 information return. Section 6033(a)(3)(B) gives the IRS discretion to ex…
IRS excuses a foreign-focused mission society from filing Form 990
An organization exempt under IRC Section 501(c)(3) asked the IRS to be relieved of the requirement to file the annual Form 990. Treasury Regulation Section 1.6033-2(g)(1)(iv) provides that a mission s…
Final adverse determination denying 501(c)(3) exemption to an organization that facilitates loan syndications for a select group of minority-owned banks
An organization applied to be recognized as a tax-exempt charity under Code section 501(c)(3). Its stated mission was to strengthen a specific category of minority-owned banks and the disadvantaged co…
Final adverse determination denying 501(c)(7) social-club exemption to a private road-maintenance association
A homeowners' group applied to be recognized (retroactively reinstated) as a tax-exempt social club under Code section 501(c)(7), the category for clubs organized for pleasure and recreation. Its memb…
Final adverse determination denying 501(c)(3) exemption to a single-family DNA genealogy project
An organization applied (using the streamlined Form 1023-EZ) to be recognized as a tax-exempt charity under Code section 501(c)(3). Its activity is a genealogical project that uses DNA testing, record…
Organization determined to be an integrated auxiliary of a church and therefore not required to file Form 990
A tax-exempt organization asked the IRS to be excused from filing Form 990, the annual information return that most exempt organizations must file. The IRS determined that the organization qualifies a…
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.