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 exemption for an insufficiently documented greenspace project
An organization sought § 501(c)(3) status for a proposed greenspace and transportation project in a densely populated urban area. It described planning, financing, construction, and eventual ownership…
202034012: IRS denies 501(c)(7) social-club status because the applicant never adequately described its activities
An organization applied to be recognized as a tax-exempt social club under IRC § 501(c)(7). Its application was largely blank: no narrative of activities, no contact person, no financial data, and an …
202034011: IRS denies 501(c)(3) status to a gated-subdivision homeowners association because it serves private, not public, interests
A homeowners association for a residential subdivision applied for 501(c)(3) charitable status. It collects yearly dues, enforces covenants, and maintains commonly owned property, including a marina a…
202034010: IRS denies 501(c)(6) business-league status to a group of bridal salons that ran a joint sales event
A nonprofit made up of independently owned bridal salons applied to be recognized as a tax-exempt business league under IRC § 501(c)(6). Its main activity was organizing an annual multi-store sales ev…
202034008: An unexpected cash grant for scholarships qualifies as an "unusual grant," protecting a school-support charity's public status
A 501(c)(3) nonprofit that supports a school by funding scholarships and special-needs projects received an unusually large cash grant from an unrelated entity. The grant was much bigger than the dona…
202034007: A large unexpected bequest counts as an "unusual grant," so it won't cost a public charity its public-support status
A public charity (one that qualifies under IRC §§ 509(a)(1) and 170(b)(1)(A)(vi)) received an unexpected all-cash bequest from a decedent's estate. The gift was so large it threatened the charity's st…
Foundation's grants for electric buses are qualifying distributions, not self-dealing with its utility founder
A private foundation was created and is funded entirely by a regulated electric and gas utility, which makes the utility a "disqualified person" the foundation generally cannot benefit. The foundation…
Neighborhood mutual-benefit corporation denied 501(c)(3) status
A group of homeowners incorporated to fight the expansion of a commercial storage facility they say was built next to their subdivision without proper zoning or permits. They applied for 501(c)(3) cha…
202032008: IRS denies 501(c)(3) status to a planned restaurant with limited charitable programs
An organization formed to address food insecurity planned to operate a farm-to-table restaurant open to the public, reserve a small percentage of tables for nonpaying families, train underserved young…
202032007: IRS denies a chamber of commerce's request to change to 501(c)(3) status
A chamber of commerce already exempt under IRC § 501(c)(6) applied to change its status to a 501(c)(3) charity. It conducted historic preservation, public events, volunteer upkeep, and education, but …
202031011: IRS denies 501(c)(3) status to an organization running rodeos and recreational events
An organization formed to promote education, recreation, the Western way of life, and equine sports applied for 501(c)(3) status. It ran rodeos, barrel racing, roping, and other prize-based events thr…
202031010: IRS denies 501(c)(3) status to a for-profit used car dealership
A domestic for-profit limited liability company operating a used car dealership and repair shop applied for 501(c)(3) status. Its only income came from car sales and repair services, and paid director…
202031009: IRS classifies a winding-down foundation's large endowment transfer as an unusual grant
A publicly supported charity expected a large grant from a nonoperating private foundation that was winding down and distributing its assets. The transfer would establish endowed funds benefiting char…
Section 265 does not bar a charitable deduction in calculating UBTI
A tax-exempt organization claimed a charitable-contribution deduction when calculating its unrelated business taxable income. Chief Counsel considered whether section 265(a)(1) disallowed the deductio…
IRS revokes an animal-rescue organization's exemption for private inurement
An organization recognized under section 501(c)(3) conducted animal rescue, rehabilitation, education, and related public activities. The IRS found that its founder and president had sole control over…
IRS revokes a patriotism organization's exemption for inactivity
An organization was formed to promote patriotism and national unity through a coordinated public event, but the planned event did not occur. The examination found one early year with fundraising activ…
A charity may exclude a one-time liquidating distribution as an unusual grant
A public charity described in section 509(a)(2) expected to receive cash and other liquid assets when another organization dissolved. The distribution was a one-time event, and its size would otherwis…
An umpire association does not qualify as a section 501(c)(4) social welfare organization
An association of certified baseball and softball umpires sought exemption as a section 501(c)(4) social welfare organization after withdrawing an earlier section 501(c)(7) application. It negotiated …
A political advertising organization does not qualify under section 501(c)(4)
An organization sought section 501(c)(4) status for public education, advocacy, grantmaking, and political activities. It distributed television advertisements, direct mail, and internet communication…
A student fishing club does not qualify under section 501(c)(7) because nearly all income comes from nonmembers
A university fishing club sought exemption as a section 501(c)(7) social club. Its members competed in fishing tournaments, organized a public tournament, volunteered at community events, promoted fis…
A dog training club does not qualify as a section 501(c)(3) educational organization
A dog club sought recognition as a section 501(c)(3) educational organization. It held meetings, maintained a practice facility, offered obedience, agility, and scent-work classes, conducted trials, a…
A commercial tour operators' association does not qualify under section 501(c)(3)
An association of commercial tour operators was formed to manage tours and related facilities on government-owned land. Its members had to pay for park maintenance, insurance, utilities, and other cos…
A retail theft analytics subscription service does not qualify under section 501(c)(3)
A nonprofit proposed a subscription database and analytics service to help retailers and law enforcement identify stolen goods, reduce return fraud, and analyze organized retail theft. It planned to c…
A farmers' market does not qualify under section 501(c)(3) because it primarily benefits vendors
A nonprofit farmers' market sought section 501(c)(3) status based on goals involving healthy food access, sustainable agriculture, community development, and public education. It operated regular mark…
A medical-office condominium association does not qualify under section 501(c)(4)
A condominium association for a medical office building sought exemption as a social welfare organization under section 501(c)(4). Its members were the unit owners, and assessments paid for landscapin…
A mutual-assistance membership group does not qualify under section 501(c)(3)
A membership organization composed of people of a shared ethnicity collected recurring fees and made payments to members for sickness, financial distress, funerals, births, marriages, and first-home p…
Clean-technology consulting organization does not qualify under section 501(c)(3)
An organization sought section 501(c)(3) status to slow climate change by accelerating clean technologies into commercial markets. It sold research, consulting, training, networking, market-access, an…
Exemption revoked for commercial historic-tax-credit business
The IRS revoked a historic-preservation organization's Section 501(c)(3) exemption after concluding that its main activity was a commercial historic-tax-credit business. The organization entered partn…
Cryptocurrency software organization denied section 501(c)(3) status
An organization applied for section 501(c)(3) status to support an open-source cryptocurrency, its blockchain software, a digital wallet, related websites, research, merchant integration, and user sup…
Social club may treat one-time carbon-offset credits as unusual income
A tax-exempt social club owned forestland that its members used for hiking, hunting, fishing, and other outdoor recreation. It proposed entering a state carbon-offset program that required long-term f…
Healthcare investor group denied business league exemption
A membership organization of accredited healthcare investors sought exemption as a business league under section 501(c)(6). It screened healthcare startups, selected companies to present at investment…
Membership business activity failed the social welfare test
The IRS examined an organization that claimed exemption as a social welfare organization under section 501(c)(4). The final determination states that the organization was not a civic league or operate…
Restaurant alcohol club denied social club exemption
A nonprofit formed a private club inside a public restaurant so members could purchase alcoholic beverages under state licensing rules. Membership was broadly available to adult county residents dinin…
Industry competition organization denied charitable reclassification
An organization already exempt as a section 501(c)(6) business league sought recognition as a section 501(c)(3) charitable and educational organization. Its primary activity was an annual skills compe…
Food truck association denied charitable exemption
A professional association of independent food truck owners and operators applied for exemption under section 501(c)(3). It promoted member businesses through catering referrals, exclusive vending eve…
Commercial fishers association denied charitable exemption
A membership organization of commercial fishers applied for exemption under section 501(c)(3). It sought to advocate for sustainable fisheries, send representatives to regional and international fishe…
Member funeral benefit plan denied charitable exemption
A mutual assistance membership organization collected fees and death-triggered contributions from members and paid funeral benefits when a member or family member died. Eligibility opened after one mo…
Franchise-owner association denied business-league exemption
An association of franchise owners for a single brand sought exemption as a business league under section 501(c)(6). It held meetings and annual forums about brand policies, vendors, operating problem…
Foundation may divide its assets among related foundations and terminate
A private foundation whose directors disagreed about its operation proposed dividing all of its assets evenly among several existing or newly formed private foundations controlled by the same people. …
Business referral group denied charitable exemption
A membership organization sought section 501(c)(3) status while helping members grow their businesses and referral networks. Its weekly meetings featured business presentations, testimonials, referral…
Energy-monitoring service denied charitable exemption
A nonprofit proposed operating a cloud-based energy monitoring platform and related analyst services for affordable housing developers. Members, including some for-profit businesses, would pay annual …
Professional networking chapter denied charitable exemption
A local chapter of a section 501(c)(6) organization sought charitable exemption under section 501(c)(3). Its mission was to build a network among people of color and others connected with a particular…
Family scholarship and hardship fund denied charitable exemption
An organization formed to provide scholarships and financial assistance primarily to members of one extended family sought section 501(c)(3) exemption. Its family-controlled board expected most schola…
Industry membership group denied charitable exemption
An association of independent operators in a particular industry sought section 501(c)(3) exemption. Its articles authorized any lawful activity and lacked a charitable dissolution clause, while its p…
Fundraiser for one family denied charitable exemption
An organization raised money through annual fundraisers to help a named person and his family pay medical expenses related to cancer treatment. Family and friends organized the events, donated goods o…
Purebred dog club denied charitable exemption
A membership club for breeders, owners, exhibitors, and enthusiasts of a particular purebred dog sought section 501(c)(3) exemption. It conducted breed shows, obedience, rally, and agility trials, alo…
Family reunion organization denied charitable exemption
An organization devoted all of its current time and resources to a biennial reunion and gala for one extended family and the family's friends. The event combined educational, social, and spiritual act…
Recreational golf league denied charitable exemption
An unincorporated association organized a recreational league and social activities for a corporation's members, their spouses, and guests. It held events three days each week as well as luncheons, ho…
Member cemetery denied charitable exemption
A nonprofit operated and maintained a cemetery offering affordable burial locations only to members, who had to be descendants or spouses of people connected to specified local places. Membership dues…
Community tavern denied charitable exemption
An organization planned to operate a community tavern and meeting place selling locally brewed beer and wine. It proposed membership levels with merchandise, voting rights, and member-only events, whi…
Business member group denied charitable exemption
An organization represented businesses from one country operating in a metropolitan area. Its articles said it protected and promoted members' interests, and its quarterly meetings taught members abou…
Retailer association denied charitable exemption
An association of retailers held quarterly meetings on marketing, personnel management, and product procurement. It also rewarded member businesses' customers with free picnics, parties, and golf outi…
Healthcare insurer denied charitable exemption
An organization planned to sell comprehensive healthcare insurance for a monthly premium and later develop healthcare facilities. Insurance premiums were projected to produce 94 percent of its income,…
Commercial production project denied charitable exemption
An organization proposed to train disabled people, particularly veterans, through paid positions on commercial production projects. It would own the resulting intellectual property, license completed …
Condominium association denied social-welfare exemption
A condominium owners association applied for exemption as a social-welfare organization under section 501(c)(4). It collected homeowners association and management fees and used them for building serv…
Breeding and showing association denied charitable exemption
An association already exempt under section 501(c)(5) asked to change its status to a charitable and educational organization under section 501(c)(3). Its articles authorized activities promoting anim…
Homeowners association denied charitable exemption
A homeowners association applied for recognition as a charitable organization under section 501(c)(3). Every lot owner in the subdivision was a member, and annual dues funded services such as snow rem…
Internet exchange point denied business-league exemption
A nonprofit internet exchange point sought exemption as a business league under section 501(c)(6). It connected members to shared switching infrastructure for internet traffic exchange and route peeri…
Member death-benefit association denied social-welfare exemption
An association collected registration fees, annual dues, and per-member assessments to pay death benefits to the designated beneficiaries of deceased members. It also offered members free seminars on …
For-profit hunting club denied social-club exemption
A for-profit corporation owned land where its shareholders could hunt, camp, ride off-road vehicles, snowmobile, and engage in conservation activities. It received no member income; all revenue came f…
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.