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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Exemption denied for commercial hall rentals benefiting a fraternal organization
A membership organization sought section 501(c)(3) status for maintaining a hall and grounds used primarily by a related section 501(c)(8) fraternal organization and rented to the public for events. I…
Business league exemption denied for member-specific power contract negotiations
An organization of municipal and cooperative electric utilities sought section 501(c)(6) status after forming to negotiate a power purchase arrangement with a natural gas plant developer. Its only act…
Exemption revoked after operations ceased and records were not provided
A section 501(c)(3) organization told the IRS that it had discontinued all activities and did not intend to operate again after its president relocated. During an examination, the IRS made repeated te…
Exemption revoked for private benefits from individualized fundraising
A sports booster organization raised money for athletes who trained at a related for-profit gymnastics and cheerleading business. Members could reduce their own required assessments through fundraisin…
Exemption revoked because a labor association served its members
A management-employee labor association had been recognized under section 501(c)(3), but its articles stated that it was organized for section 501(c)(5) purposes and directed assets on dissolution to …
Exemption revoked for uncontrolled grants and unexplained officer spending
A public charity said it would make grants to institutions and individuals using board approval, reports on the use of funds, and records showing that recipients and purposes were charitable. During a…
Social club exemption revoked for excessive nonmember income
A motorcycle club held competition events and provided campgrounds, grilling, showers, and other amenities for riders and their families. The events were open to nonmembers, advertised on the club's w…
Exemption denied for substantial member-only benefit funds
An organization proposed public healthcare, rural development, cultural education, family assistance, farmer cooperatives, business training, advocacy, and other programs in the United States and anot…
Farmers' market denied section 501(c)(3) status for serving vendors' private interests
An organization sought reinstatement of section 501(c)(3) status after its earlier exemption was automatically revoked for failing to file Form 990 for three consecutive years. Its main activity was o…
Exemption denied because applicant supplied no organizing document
An applicant for section 501(c)(3) status stated that it was not a corporation, limited liability company, unincorporated association, or trust. It did not submit an organizing document, bylaws, or pr…
Single-brand franchisee association denied business-league exemption
An association of current and former franchise owners sought exemption as a business league under section 501(c)(6). It conducted meetings, required-certification workshops, member updates, and trade …
For-profit egg-grader business denied agricultural-organization exemption
A for-profit corporation repaired commercial egg graders and sold refurbished graders and parts to egg producers. Its two directors were a married couple who also owned the stock, received monthly pro…
Exemption denied because incomplete application did not establish exempt operations
A nonprofit corporation applied for section 501(c)(3) status with broad community-assistance purposes and an unfiled set of articles referring to a church. Its application omitted a narrative of activ…
A homeowners' association was denied social club exemption
A homeowners' association applied for exemption as a social club under section 501(c)(7). Its main activity was maintaining residential property and setting aside funds for repairs and replacements, a…
A resident-owned mobile home park corporation was denied exemption
A member-owned corporation sought section 501(c)(3) status so it could buy the land under a mobile home park and keep lot rents stable for resident homeowners. The residents would continue to own thei…
A hospital owner lost exemption after ceding control to a for-profit operator
A nonprofit hospital owner had been exempt under section 501(c)(3) since 1989 but later leased its hospital land, property, and equipment to a for-profit operator. The for-profit collected hospital re…
Military fishing tournament did not qualify for section 501(c)(3)
A nonprofit corporation organized an annual three-day event for military service members that included a dinner, a military-installation tour, and a fishing tournament. The IRS found that the organiza…
Pharmacy's commercial operations prevented section 501(c)(3) exemption
A nonprofit corporation planned to operate a pharmacy open to the general public. It would charge usual prices to insured and Medicare customers and pharmacy cost to poor, indigent, and underinsured c…
For-profit governing documents defeat section 501(c)(3) exemption
The IRS denied section 501(c)(3) status to an organization that offered dance, cultural, educational, and youth programs. The organization was incorporated under a state's for-profit corporation law, …
Apartment rentals to the general public cause exemption revocation
The IRS revoked an organization's section 501(c)(3) exemption because its only observed activity during and after the examination years was renting its facility as apartment housing to members of the …
Inactive organization loses exemption after failing to substantiate operations
The IRS revoked an organization's section 501(c)(3) exemption after the organization reported that it had conducted no activities or financial transactions since formation and had no bank account or f…
Commercial school services cause exemption revocation
The IRS revoked an educational organization's section 501(c)(3) exemption after its operations shifted toward fee-based transportation, technology-network, and property-leasing services for school dis…
Trust owes UBIT on partnership and debt-financed income
An exempt trust reported unrelated business taxable income from partnership interests and debt-financed property, paid the resulting tax, and later claimed a refund. The IRS concluded that section 501…
Funeral-benefit membership group denied tax exemption
A membership organization collected membership fees and additional payments when a member died, then paid a fixed funeral benefit to the member's family. Its articles stated that its purpose was to ra…
Charity loses exemption over activities and fiscal sponsorships
The IRS revoked an organization's section 501(c)(3) status after concluding that its cash disbursements were not shown to be exclusively charitable. The organization conducted overseas aid and scholar…
Rezoning agreement does not make foundation property debt-financed
A private foundation owned debt-free real property leased to unrelated businesses and hired an unrelated developer to pursue higher-density rezoning. The developer would initially bear most rezoning c…
Exemption denied to fee-funded mortgage broker
A nonprofit applicant planned to originate mortgages for the general public and receive a one-percent loan origination fee from lenders for each loan it brokered. Its founder was also the owner of a f…
Exemption revoked after organization ignored audit requests
A section 501(c)(3) organization was selected for examination but did not respond to repeated letters and telephone calls seeking records needed to audit its Form 990. Some certified letters were retu…
Exemption denied for defective organizing terms and inadequate records
An organization applied to regain section 501(c)(3) status after an automatic revocation for failing to file required annual returns. Its articles directed assets on dissolution to a named organizatio…
Export-promotion organization failed both section 501(c)(3) tests
An organization was formed to support a section 501(c)(6) group and a government office in promoting U.S. exports, initially through a sponsored conference. It planned to collect registration and spon…
Exemption revoked after the organization ignored audit requests
A section 501(c)(3) organization was selected for an examination of its Form 990-N but did not provide the information needed for the audit. The IRS sent repeated letters to the organization, a second…
Real estate association denied section 501(c)(6) exemption because its MLS served members
A real estate association applied for exemption as a business league under section 501(c)(6). Its activities included advocacy, education, member meetings, community events, public information, and ac…
Condominium association denied section 501(c)(4) exemption because it served unit owners
A ten-unit condominium association applied for exemption as a social welfare organization under section 501(c)(4). It maintained the common areas and building exterior, and each unit owner held an int…
Administrators association denied section 501(c)(4) exemption because it primarily served members
An association of certified educational administrators applied for exemption under section 501(c)(4). It represented members and fee-paying nonmembers in collective bargaining over contracts and salar…
Fire department assistance fund denied section 501(c)(3) exemption because it primarily benefited members
A fund associated with a fire department applied for exemption as a charitable organization under section 501(c)(3). Its governing documents focused on helping members and their immediate families wit…
Car shows serve a substantial recreational purpose
The IRS denied section 501(c)(3) status to a car club whose primary activity was hosting shows for members, car enthusiasts, and the public. The club planned seminars and said some proceeds would bene…
Dental organization loses exemption for commercial operation and inurement
The IRS revoked a dental organization's section 501(c)(3) status after concluding that it operated like a commercial dental practice and allowed its earnings and assets to benefit private individuals.…
Timeshare charity loses exemption for private benefit and commercial activity
The IRS revoked the exemption of an organization that solicited timeshare donations, sold the properties, and distributed some net proceeds to charities chosen by donors. Its sole voting member also o…
Unexpected scholarship gift qualifies as an unusual grant
A publicly supported charity that provided professional scholarships expected to receive a cash gift far larger than its annual budget and normal grants. The donor had not created or controlled the ch…
Private-road homeowners association denied exemption
A homeowners association with four member properties applied for section 501(c)(3) status. One related business owned two of the four homes, and related individuals controlled the association's board.…
Referral networking group denied business-league exemption
A business networking group allowed only one representative from each industry or professional classification. Its weekly meetings included member sales pitches, referrals, testimonials, and introduct…
Innovation consulting organization denied exemption
An organization proposed to help commercialize life-science and emerging-technology innovations through innovation hubs, research evaluation, healthcare-access models, and industry-academic data conso…
Public trap-shooting events defeated social-club exemption
An unincorporated trap-shooting club sought exemption as a social club under section 501(c)(7). Most of its events were open to anyone who paid the fee and followed the rules, and nonmember receipts e…
Charity lost exemption after failing to provide audit records
The IRS repeatedly asked a section 501(c)(3) organization for records needed to examine its receipts, expenditures, activities, and Form 990. Although the organization's president spoke with the exami…
Charity lost exemption after ignoring audit requests
A section 501(c)(3) organization did not provide the financial and activity information requested during an examination of its Form 990-N. The IRS mailed several requests and made repeated telephone c…
Foreign stock purchases and private benefits caused revocation
A section 501(c)(3) organization sent substantial charitable funds to accounts abroad for the purchase of shares in a publicly traded company. The examination report states that the treasurer knew the…
Artists' sales show primarily benefited members
An organization served as an umbrella for local artists and promoted one annual open-studio sales show. It had obtained exemption partly in hopes of securing grants, but no grant opportunity was pursu…
Restaurant business overwhelmed claimed exempt activities
A section 501(c)(3) organization described youth mentoring, workshops, school-supply distributions, and restaurant-based workforce training as its exempt programs. It did not provide evidence that tho…
Industrial park association was denied social-welfare exemption
An association of industrial park lot owners applied for exemption as a social-welfare organization under section 501(c)(4). It maintained the park's common areas, paid utilities and other operating c…
Military morale club was denied charitable exemption
An unincorporated association limited membership to military personnel at a particular location who held a specified rank. It organized picnics, paintball trips, gaming and sports tournaments, and oth…
Single-vendor software group was denied business-league exemption
A software user group sought exemption as a business league under section 501(c)(6). Membership was limited to organizations licensed to use a particular commercial software system, and most forum act…
Hospital lost its exemption for failing the community health needs assessment rules
The IRS revoked a hospital organization's section 501(c)(3) status because it did not satisfy the community health needs assessment requirements of section 501(r). The hospital had obtained an assessm…
Organization loses exemption after failing to provide audit records
The IRS revoked an organization's section 501(c)(3) exemption after it repeatedly failed to provide requested financial records and information about its activities. The organization did not respond t…
Farmers market loses exemption for commercial private benefit
A nonprofit operated several farmers markets where farmers, food producers, artisans, and other vendors sold goods directly to the public. Vendors paid membership dues and market fees, while the organ…
Charitable trust may track a school's endowment without generating UBTI
A charitable remainder unitrust had a school as its trustee and sole charitable remainder beneficiary. The school proposed issuing contractual endowment units so the trust could receive returns matchi…
School may issue endowment units to charitable trusts without UBTI
A tax-exempt school served as trustee and sole charitable remainder beneficiary of a charitable remainder unitrust. It proposed issuing contractual units tied to its pooled endowment so the trust coul…
Large bequest qualifies as an unusual grant
A publicly supported charity expected a large bequest from a donor who did not create or control the organization. The charity had consistently met the public-support test, actively solicited public c…
Transitional-housing exemption denied for vague plans and private benefit
A nonprofit sought recognition under IRC § 501(c)(3) for a planned transitional-housing program. It repeatedly said that it would develop its facility, admissions policies, fees, services, staffing, a…
Marine-services exemption denied for commercial operations
A nonprofit provided project planning and arranged underwater engineering and marine-science services for academic and research clients. It hired third-party contractors, charged clients its costs plu…
Fishing-market organization denied agricultural exemption
An organization formed to preserve a commercial fishing fleet bought seafood from local fishermen above open-market prices and resold it to the public, both uncooked and as prepared meals. The IRS con…
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.