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 rehab charity's exemption after a for-profit took over its operations
This final adverse determination revokes the 501(c)(3) exemption of a nonprofit spinal-injury rehabilitation center. The organization had been converted from a for-profit clinic that used a copyrighte…
IRS revokes a charity's 501(c)(3) status after an audit it never completed
This final adverse determination letter revokes an organization's 501(c)(3) tax-exempt status. The group had applied on the streamlined Form 1023-EZ and been recognized as exempt, then was selected fo…
IRS revokes a charity's 501(c)(3) status for failing to answer an audit
This is a final adverse determination letter revoking an organization's tax-exempt status under section 501(c)(3). The group had received a favorable exemption ruling and said it was formed to provide…
Gymnastics organization's exemption revoked for private inurement and benefit
The IRS revoked the Section 501(c)(3) exemption of an organization that provided gymnastics instruction. The organization had replaced a related for-profit business in the same space while retaining i…
IRS denies 501(c)(3) status to a club whose charity was incidental to its social events
The IRS denied tax-exempt status under section 501(c)(3) to an unincorporated membership club. The group described itself as a social organization that promotes individuality and self-expression throu…
IRS denies "unusual grant" treatment for a repeat donor's endowment gift
A publicly supported educational charity asked the IRS to treat a large one-time gift as an "unusual grant." That label matters because public charities must keep a broad base of public support to hol…
Section 501(c)(5) exemption denied to a commercial farm operation
A mutual benefit corporation applied for exemption as an agricultural organization under Section 501(c)(5). It had no members, grew and sold its own crop, paid its founder and sole director a salary, …
Foundation receives rules for inherited business interests, apartment rent, and mortgage debt
A private foundation is the remainder beneficiary of a trust that will distribute corporate and limited liability company interests after the death of the current beneficiary. The assets include an in…
Business networking association is denied social club exemption
A business association sought exemption as a social club under section 501(c)(7). Its weekly meetings focused on exchanging business information, generating leads, and expanding trade among members, w…
Family cemetery denied 501(c)(3) exemption
An organization formed to operate and maintain a small historical cemetery for the direct descendants of one family applied for tax-exempt status under section 501(c)(3) using the streamlined Form 102…
Fishing-tournament organization denied 501(c)(3) exemption
An organization applied for tax-exempt status under section 501(c)(3), saying it promotes civic improvement, social interaction, and the sport of fishing, and that it funds a college scholarship. In p…
IRS revokes a community theater's 501(c)(3) status for running commercial tribute-band concerts and benefiting its founders' catering company
A community theater arts nonprofit had been recognized as a tax-exempt charity under Code Section 501(c)(3) since the 1990s, originally for producing plays and musicals for the public. To cut costs, i…
IRS revokes a family scholarship foundation's 501(c)(3) status for serving one family and spending funds on personal matters
A small foundation gave college scholarships only to descendants of one particular family and also compiled the family's genealogical records. The IRS revoked its 501(c)(3) charitable exemption on two…
IRS denies 501(c)(7) social club status to a football officials' association that mostly collects officiating fees
A group of trained football officials organized so that school districts could hire them to officiate scholastic games; the district pays fees to the group, which passes them on to the member-official…
IRS denies 501(c)(3) status to a commercial-style dispute-resolution organization
To be a tax-exempt charity under Internal Revenue Code § 501(c)(3), an organization must be both organized and operated exclusively for charitable or educational purposes. This organization, a former …
IRS revokes a social club's 501(c)(7) status for too much nonmember (public) golf revenue
A social or recreational club can be tax-exempt under Internal Revenue Code § 501(c)(7) only if it is supported mainly by member dues and keeps income from outsiders modest: no more than 35% of gross …
IRS revokes a fraternal society's 501(c)(8) status because it does not operate under the lodge system
A "fraternal beneficiary society" can be exempt from federal income tax under Internal Revenue Code § 501(c)(8) only if it meets two requirements: it must operate under the "lodge system" (local, larg…
IRS revokes a golf/social club's 501(c)(7) status for excessive public (nonmember) use of its facilities
A social or recreational club is tax-exempt under Internal Revenue Code § 501(c)(7) only if it is supported mainly by members and keeps outside income modest: no more than 35% of gross receipts from o…
A VEBA may count insurance premiums in its medical-benefit reserve when figuring taxable income
A voluntary employees' beneficiary association (VEBA) is a tax-exempt trust under § 501(c)(9) that funds benefits like health, life, and disability coverage for workers. A VEBA can set money aside for…
201843016: Revokes an eco-tourism nonprofit's 501(c)(3) exemption for commercial services and private benefit
This is a final IRS determination revoking the section 501(c)(3) exemption of a nonprofit that promoted sustainable travel and eco-tourism. The organization sold certifications, assessments, training,…
IRS revokes a heritage club's 501(c)(8) status for having no lodge system and paying no member benefits
A "fraternal beneficiary society" qualifies for tax exemption under Internal Revenue Code § 501(c)(8) only if it both operates under the "lodge system" (local, largely self-governing branches chartere…
IRS revokes a nonprofit's 501(c)(3) status after it ignored an audit
A charity exempt under Internal Revenue Code § 501(c)(3) must keep adequate records and, when the IRS examines it, provide enough information to show it is still organized and operated for exempt purp…
IRS denies 501(c)(3) status to a charity formed mainly to fund its founder's medical costs
To be tax-exempt under Internal Revenue Code § 501(c)(3), an organization must operate exclusively for public purposes, and none of its earnings may benefit private individuals (the "inurement" and "p…
201843012: Revokes a motorcycle club's 501(c)(7) exemption for running a public motocross park
This is a final IRS determination revoking the tax-exempt status of a nonprofit motorcycle/off-road club that had been recognized under section 501(c)(7) as a social and recreation club. On audit, the…
201843011: Revokes 501(c)(3) status of a shell nonprofit that fronted for a for-profit fundraising platform
This is a final IRS determination revoking the 501(c)(3) exemption of a nonprofit that had been recognized as a public charity to educate the public about amateur athletics and to fund school, youth, …
201843010: Revokes a children's-cancer charity's 501(c)(3) for private inurement, inflated gift-in-kind reporting, and fundraising against public policy
This is a final IRS determination revoking the 501(c)(3) exemption of a nonprofit organized to help children suffering from cancer and their families. On audit, the IRS found the organization was oper…
201841008: Denies 501(c)(3) status because the applicant did not document a valid nonprofit corporation
An organization applied for section 501(c)(3) status while its filed articles showed it as a stock-issuing for-profit business corporation. The articles had neither a clause limiting the organization …
201841007: Denies 501(c)(3) status because the articles lacked exempt-purpose and dissolution clauses
A nonprofit corporation applied for section 501(c)(3) status but submitted its bylaws instead of its articles of incorporation. The IRS obtained the articles from the state and found that they did not…
501(c)(3) exemption denied to an organization that conducted no activities and did not respond to IRS requests
An organization applied for 501(c)(3) tax-exempt status using the streamlined Form 1023-EZ, attesting that its organizing documents met the requirements. When the IRS asked for details about its actua…
501(c)(3) exemption denied to a nonprofit art gallery
An organization that started as a for-profit LLC art gallery converted to a nonprofit and applied for 501(c)(3) charitable exemption. It ran a gallery showing and selling the work of local "exhibiting…
501(c)(3) exemption denied to a wedding-industry networking group
A group formed as a nonprofit mutual benefit corporation to connect professionals in the wedding industry (caterers, bakers, photographers, venues, and the like) applied to be recognized as a tax-exem…
Journal advertising is not the exempt society's unrelated business income
A 501(c)(6) professional society publishes a scholarly journal through a contract with a for-profit publisher. The society controls the editorial content, but under the contract the publisher alone se…
Gas-lease royalty group denied 501(c)(6) exemption for performing particular services for members
A membership group formed to help mineral-lease owners fight improper deductions from the gas royalties they were owed under a particular lease form. It collected dues, hired lawyers and accountants t…
201835012: Denies 501(c)(3) status because adult recreational sports were a substantial purpose
A corporation sought section 501(c)(3) status to promote health and fitness through church leagues, tournaments, exercise programs, and recreation for both adults and children. Its immediate focus was…
201835011: Denies VEBA status because participating employers lacked a common employment bond
A trust sought section 501(c)(9) status as a voluntary employees' beneficiary association offering medical, dental, vision, life, and other welfare benefits to small employers across many industries i…
201835010: Denies section 521 exemption to a consumer-oriented local food co-op
A local food co-op sought exemption as a farmers' cooperative under section 521. Most of its members were consumers, and the organization connected them with producer members through an online marketp…
201835009: Denies 501(c)(3) status to a fee-based transportation business
A nonprofit corporation sought section 501(c)(3) status for a business offering transportation, employment, invention, mentoring, paralegal, and lending services. Its articles stated broad business pu…
201835008: Denies 501(c)(3) status to a fee-funded biotech consulting business
An organization sought section 501(c)(3) status for consulting, executive search, coaching, and educational services aimed at biotech and pharmaceutical companies developing treatments for rare diseas…
201835007: Denies 501(c)(7) status to a sports officials association operating a business
An association of sports officials sought exemption as a social club under section 501(c)(7). It spent 70 percent of its time providing member officials to public and private schools, collected the of…
201835006: Denies 501(c)(3) status to a mutual-benefit cattle farm
A mutual-benefit corporation sought section 501(c)(3) status for a cattle farm that would buy, breed, and sell cattle, with future plans to donate meat, support schools, and provide farm education. It…
Revokes charity status for donor-controlled partnership program
The IRS revoked the section 501(c)(3) status of an organization used in charitable-giving arrangements involving limited partnerships and limited liability companies. Donors transferred nonvoting inte…
Revokes an inactive charity's tax exemption
The IRS revoked the section 501(c)(3) status of an organization formed to operate nursing and retirement facilities for elderly people. The organization reported transferring its assets to a related n…
Denies exemption to commercial billboard network
An organization sought section 501(c)(3) status for a network of outdoor digital displays that would carry commercial advertising, nonprofit messages, and political-candidate messages. It planned to c…
Revokes inactive organization's exemption
An organization had previously lost exemption automatically for failing to file returns, then reapplied and received retroactive reinstatement under section 501(c)(3). Its stated plans included commun…
Revokes commercialized social club exemption
The IRS revoked the section 501(c)(7) exemption of a social club that operated alongside a taxable restaurant and bar. The public could purchase alcohol without becoming members or paying dues, the cl…
Revokes work-unit morale organization's exemption
An organization received section 501(c)(3) status after filing Form 1023-EZ, but its bylaws focused on improving the health, welfare, and morale of members of a specified work unit and their families.…
Revokes firefighter member-benefit charity's exemption
An organization formed a charity to accept contributions for members' families when a firefighter died in the line of duty or members experienced other catastrophic events. The IRS found that the orga…
Revokes inactive fire association's section 501(c)(4) status
An organization had been recognized under section 501(c)(4) for volunteer fire protection and related civic purposes, but it disbanded after the fire chief stopped using volunteer firefighters. Its on…
Revokes dual-status hospital's section 501(c)(3) exemption
A county-owned hospital also held section 501(c)(3) status, making it a dual-status governmental hospital. The hospital was not required to file Form 990 because of its governmental status, but it sti…
Revokes noncompliant county hospital's charitable exemption
A county-created regional hospital was both a governmental entity and a section 501(c)(3) organization. Although its governmental status excused it from filing Form 990, it still had to comply with se…
Revokes energy-referral charity for private benefit
An organization said its mission was to inform consumers about possible savings on electric and gas bills. In practice, it called consumers and sent interested prospects to two related energy business…
Denies exemption for high school class reunions
An unincorporated association applied for section 501(c)(3) status to organize periodic high school class reunions for classmates and their families. It planned annual or twice-yearly fundraisers to r…
Revokes inactive aromatherapy foundation's exemption
A foundation was recognized under section 501(c)(3) to provide aromatherapy education, public seminars, professional training, and research support. After a county changed its transient-occupancy lice…
Preserves VEBA exemption and avoids UBTI for health benefit subaccount
A voluntary employees' beneficiary association funded retiree health benefits for collectively bargained employees. It proposed transferring assets once to a new internal subaccount that would pay hea…
Denies exemption to market-rate veterinary practice
A professional service limited liability company applied for section 501(c)(3) status to provide veterinary services and eventually find homes for abandoned animals. Its sole member shared in profits …
Denies business league exemption to farmers' market
A farmers' market sought exemption as a business league under section 501(c)(6). It provided member vendors with physical and online selling venues, advertising, electrical access, and other market se…
Denies social welfare exemption to commercial property association
An association of commercial property owners sought exemption as a social welfare organization under section 501(c)(4). It planned to maintain privately owned common areas, parking, landscaping, utili…
Denies social welfare exemption to condominium association
A condominium owners' association sought exemption as a social welfare organization under section 501(c)(4). It collected assessments to maintain the complex's exterior structures, grounds, pool, tenn…
Denies exemption to member-focused internet exchange
An organization sought section 501(c)(3) status to establish and operate a neutral regional internet exchange. Members would pay port fees, receive below-market access, and exchange local internet tra…
Denies social welfare exemption to member-owned well and dock association
A homeowners' association collected mandatory annual fees to pay expenses for a well and boat dock owned in common by its member households. It did not own the facilities, restricted their use and ass…
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.