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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Denies charity status to medical software support organization
An organization sought reinstatement of section 501(c)(3) status for its work supporting free, open-source electronic medical-record software. The software helped physicians operate medical practices,…
Denies charity status to fee-based crowdfunding platform
An organization proposed to provide an online crowdfunding platform to high-profile individuals and organizations raising money for charitable causes. It would deduct a management fee and payment-proc…
Denies exemption for vague youth aid and training programs
An organization applied for section 501(c)(3) status to support young people through savings assistance, activities, scholarships, mentoring, and job training. The IRS found that its articles did not …
Trade association denied Section 501(c)(6) exemption because it primarily advertised members
An association of businesses along a scenic highway sought exemption as a business league under section 501(c)(6). Its members included galleries, lodging providers, restaurants, fishing lodges, and r…
IRS denies business-league exemption to an umpires association that arranged member jobs
An association of baseball and softball umpires sought tax exemption as a business league under IRC Section 501(c)(6). It represented members before a state athletics body, negotiated and billed schoo…
IRS denies social-welfare exemption to a small condominium association
A condominium association with fewer than 20 units applied for tax exemption as a social-welfare organization under IRC Section 501(c)(4). The association collected member dues to maintain a small com…
IRS denies charitable exemption after applicant fails to document its organization and activities
An organization applied for recognition as a charity under IRC Section 501(c)(3), but it did not provide its articles of incorporation or attest that they contained the required purpose and dissolutio…
IRS revokes charity whose only activity was a business networking event
A tax-exempt organization described its purpose as promoting trade, commerce, tourism, and friendship between countries. During the examined year, its only activity was a free trade, commerce, and cul…
IRS reclassifies fundraising charity as a private non-operating foundation
A private foundation raised money through solicitations, events, ticket sales, and merchandise. It distributed most of the proceeds to a public charity supporting cancer research and also funded a mem…
IRS revokes group-home charity that never began operations or answered examination requests
A charity was formed to operate a group home offering life-skills training to teenage girls. It reported no income and no operations for several years, did not file one required Form 990, and did not …
IRS corrects scholarship group's public-charity classification to Section 509(a)(2)
A group of educators raised funds through a scholarship luncheon, a dance, and a regional conference, then awarded scholarships and book awards to students entering education. On its streamlined exemp…
IRS revokes business league operated as a member referral and advertising network
A membership organization brought together one representative from each of many different businesses. Members met weekly to advertise their businesses, exchange referrals, give short commercials, and …
IRS revokes charity that repeatedly refused to provide examination records
An organization recognized under section 501(c)(3) did not provide the records and information the IRS needed to examine its activities and operations. The IRS sent repeated letters, contacted board m…
Hotel restoration project is denied Section 501(c)(3) status
An organization bought a vacant, deteriorated hotel near a historic business district and planned to renovate it into ten guest rooms, a dining room, and possibly a coffee shop, wine cellar, and spa. …
Bionic-hand developer is denied exemption for private benefit and nonexempt purposes
An organization planned to develop open-source bionic hands and related control software for people with limb differences through worldwide collaboration, university programs, and hackathons. Its init…
IRS revokes organization dissolved by court as fraudulent
An organization had been recognized under section 501(c)(3) to help convicted felons and their families pursue rehabilitation, housing, careers, counseling, and other goals. A state court later found …
Homeowners' club loses exemption for enforcing covenants
A homeowners' social club operated a swimming pool, recreation area, and other facilities for members, their families, and guests. Its articles and bylaws also gave it authority to enforce the develop…
Dog-event club denied exemption for public business activity
An unincorporated purebred-dog club applied for section 501(c)(7) social-club exemption. It held recurring lure-coursing and conformation events open to members and the public, and event receipts supp…
Charity loses exemption for commercial catering operation
An organization had charitable, educational, religious, cultural, and relief purposes in its governing documents. An IRS examination found that its primary activity was operating a catering hall with …
Inactive child-feeding charity loses exemption after fraud case
A charity participated in federal afterschool and summer feeding programs intended to provide meals to children in low-income areas. Its leader pleaded guilty to conspiring to obtain program funds thr…
Inactive charity loses exemption for no operations or records
An organization received section 501(c)(3) recognition but reported that it had conducted no activity from startup through a later ownership transfer. During a long examination, the IRS repeatedly tri…
Organization denied fraternal exemption because it lacks a lodge system
An organization formed to unite descendants of three families, help members, support immigrants, offer scholarships, conduct community activities, and earn rent from its building applied for exemption…
Homeowners association denied social-welfare exemption because it primarily benefits its members
A homeowners association sought exemption as a social-welfare organization under section 501(c)(4). It maintained common areas and provided services such as landscaping, snow removal, exterior work, a…
Religious organization loses exemption after commercial activity, private inurement, and inadequate records
A religious organization operated a retail book and gift shop, arranged pilgrimage tours, and received fees for tax-return preparation. The IRS found that these activities were conducted substantially…
Organization loses exemption after ignoring audit requests and failing to substantiate its operations
An organization recognized under section 501(c)(3) was selected for examination of its activities and Form 990 reporting. The IRS sent several examination letters, including certified mail received by…
Private foundation loses exemption for founder benefit, nonexempt activity, and inadequate records
A charitable trust was recognized as a private foundation based on plans to make grants to public charities. During examination, a founder said the foundation had never distributed any grants and that…
Newly affiliated charity receives 30 days to revoke an old section 501(h) lobbying election
A health charity affiliated with another exempt health organization and changed its name after the affiliation. Within weeks, the organizations discovered that the charity had made a section 501(h) lo…
Gated homeowners association denied social-welfare exemption because its amenities serve members, not the public
A homeowners association maintained streets, gatehouses, landscaped grounds, pools, trails, courts, parks, and other amenities within a gated residential and office development. Residential owners and…
Banquet-center business prevents charitable exemption
A membership organization sought recognition under section 501(c)(3) while operating a banquet center that it rented to the general public for weddings, business meetings, parties, and similar events.…
Bingo and political activities prevent social-welfare exemption
A political-party membership organization sought exemption under section 501(c)(4). Its main activity was weekly traditional and instant bingo, which consumed most of its staff and volunteer time and …
Private foundation loses exemption after failing to substantiate charitable use of assets
A private nonoperating foundation told the IRS it would operate exclusively as a grantmaking organization. During examination, its returns reported no grants or contributions in the examined periods, …
Missing organizing documents and finances prevent charitable exemption
An organization applied for section 501(c)(3) status using Form 1023-EZ and said it conducted youth camps and leadership conferences. During review, the IRS requested its filed organizing document, an…
Missing purpose and dissolution clauses prevent charitable exemption
An organization applied for section 501(c)(3) status using Form 1023-EZ and supplied its articles of incorporation during review. The IRS found that the articles contained neither a clause limiting th…
Community internet provider is denied social-welfare exemption
A nonprofit corporation sought exemption under section 501(c)(4) while operating a fiber-optic network through a disregarded LLC. It sold internet, Voice Over Internet Protocol telephone, and maintena…
Arts contest is denied exemption for benefiting a related company
An organization planned to fund and promote creative people by running contests for artistic content. Contestants had to submit through a portal owned by a related for-profit company, which could char…
Veterans organization loses exemption over public bingo operations
A veterans organization recognized under section 501(c)(19) operated a bingo hall and snack bar used by itself and multiple unrelated exempt organizations and open to the public. It maintained the fac…
Charity loses exemption after failing to produce audit records
An organization obtained section 501(c)(3) status after filing Form 1023-EZ and was later selected for an audit of a Form 990-N filing. The IRS sent multiple examination letters to the organization an…
Closed college loses exemption after liquidation and nonresponse
A college entered bankruptcy, suspended classes, and sold all but one building under a court-approved liquidation plan. It no longer had a governing body, faculty, curriculum, enrolled students, or a …
Farmers market loses exemption for commercial private benefit
A nonprofit operated a weekly farmers market where local farmers, food producers, artists, and other vendors sold goods to the public. Vendors paid annual membership dues and weekly stall fees, and th…
Inactive service organization loses its exemption
An organization was formed to provide job-training facilities, residential treatment, and interpreter services for hearing-impaired people. During the examined year, it conducted no training, provided…
Inactive mentoring organization loses its exemption
A section 501(c)(3) organization focused on low-income and minority populations and provided mentoring to young people through workshops and other activities. It ceased operations because of operating…
Inactive disability-services organization loses its exemption
A section 501(c)(3) organization was formed to provide social services and education addressing the needs of people with mental or physical disabilities. It had provided residential treatment services…
Business networking group denied tax exemption
A membership organization brought together business owners and professionals from many industries for monthly networking meetings, referrals, introductions, and business presentations. Members sought …
Recurring oil and gas royalties cost social club its exemption
A section 501(c)(7) social club operated recreational facilities for members and received revenue from dues, assessments, cabin rentals, and oil and gas rights. For several years, royalties and an oil…
Organization loses exemption after withholding examination records
An organization had previously lost its section 501(c)(3) exemption, unsuccessfully challenged that revocation in Tax Court, and later obtained a new exemption. During a later examination, an officer …
Inactive charity loses exemption after incomplete filings
A section 501(c)(3) organization had once collected clothing and goods for a shelter but later had no receipts, expenditures, or activities. Its president told the examining agent that maintaining exe…
Organization that never operated loses its exemption
A section 501(c)(3) organization did not respond to repeated letters and telephone messages seeking information for an examination. An officer eventually confirmed that the organization was inactive, …
Stalled housing charity loses its exemption
A section 501(c)(3) organization was examined to determine whether its activities matched its approved exempt status. Its sole officer said the organization had received a redacted amount of revenue, …
Organization loses exemption for nonexempt operation and inurement
The IRS revoked an organization's section 501(c)(3) exemption after concluding that it had not established operation exclusively for exempt purposes. The final letter also states that the organization…
Artist cooperative gallery denied charity status
A nonprofit gallery succeeded a for-profit gallery and provided member artists with display space, advertising, shopkeeping, marketing, and sales services. Working and consignment members set prices a…
Foreign funding conduit and undocumented cash cause revocation
A domestic section 501(c)(3) organization solicited contributions in the United States to support the known activities of a foreign organization. It did not make proposal-based grants, document how th…
Social club loses exemption over nonmember income
A tax-exempt social club received more than the permitted share of its gross receipts from nonmembers through bar sales and green fees. The examination report said the club exceeded the 15 percent non…
Vehicle-brand dealer group denied exemption
An association of vehicle dealers sought exemption as a business league under section 501(c)(6). Its membership was limited to dealers of one brand in a particular area, and its sole activity was adve…
Veterans post loses exemption over public bar and gambling operations
A veterans post held section 501(c)(4) status but operated a bar and gambling business that was open to the public six days a week. Although the post reported some community projects, the IRS found th…
Hockey-referee group denied exemption for serving members' private interests
A membership organization supplied paid referees to youth hockey associations, collected the contract fees, assigned games to its referee members, and paid those members for their work. The group argu…
Education-fund group loses exemption for benefiting its workers
An organization arranged for members, usually parents of students, to staff concession stands at professional sporting events. It tracked each worker's hours, credited a corresponding amount to that w…
Exemption revoked after organization withheld required records
The IRS repeatedly asked a section 501(c)(3) organization to provide records, financial statements, minutes, and documents needed to correct its articles' purpose clause. The organization received a c…
Dog rescue loses exemption for commercial operation and private benefit
A self-declared section 501(c)(4) dog rescue charged fees to surrender and adopt selected breeds, did not accept strays, and stated no fee reductions based on income or need. It had never filed Form 9…
Exemption revoked after organization ignored audit document requests
A recognized section 501(c)(3) organization was selected for an audit of its Form 990-N filing. The IRS mailed two document requests, made repeated telephone calls, confirmed the organization's addres…
Exemption denied for an inadequate dissolution clause and unsupported individual assistance
An organization applied for section 501(c)(3) status using Form 1023-EZ and attested that its organizing document contained the required dissolution provision. The IRS found that the actual organizing…
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.