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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Inactive organization loses tax-exempt status
The IRS revoked an organization's tax-exempt status under IRC § 501(c)(3) because it had been inactive for years and was not operating exclusively for exempt purposes. Its returns reported no revenues…
Member death benefits and investments defeat charitable exemption
A membership organization applied for exemption under IRC § 501(c)(3) while providing cash death benefits, support for arrests and medical or immigration issues, and investment opportunities to its me…
Public rentals and excess nonmember income revoke club exemption
A social club conducted community programs, hosted public speakers and classes, made its clubhouse available to outside groups, and awarded local scholarships. It also rented facilities to members and…
Condominium association serves owners, not public social welfare
A small condominium association sought exemption as a social-welfare organization under IRC § 501(c)(4). Owner dues paid for insurance on a retention pond, street-light electricity, pond cleaning, and…
Endowment units do not create unrelated business income for charitable trust
A charitable remainder unitrust proposed exchanging assets for contractual units tied to its charitable remainder beneficiary's diversified endowment. The trust would have no ownership or control over…
Cost-only endowment services do not create unrelated business income
A public charity proposed allowing a charitable remainder unitrust to participate indirectly in the charity's diversified endowment through contractual units. The charity would issue units for trust a…
Golf club denied social-club exemption
A golf club sought exemption under section 501(c)(7) after previously operating as a for-profit entity. It regularly opened its golf course, fishing access, tournament, clinic, and clubhouse to nonmem…
Social club loses exemption for public business activity
A social club regularly provided its facilities and services to the general public for established fees. Its nonmember income exceeded the 15 percent limit, and the organization lacked reliable contro…
Charity loses exemption over car sales and missing records
A charity said it would help lower- and middle-income families and direct proceeds from donated vehicle sales to charities chosen by donors. Its car operation instead functioned like a used-car dealer…
Charity loses exemption for serving a telemarketer's private interests
A charity's only activity was a corporate sponsorship program operated by a related for-profit home-improvement company. The company used its employees to make solicitation calls in the charity's name…
Scholarship fund tied to a beauty pageant is denied tax-exempt status
An organization sought recognition as a tax-exempt charity to raise and distribute scholarships, most of which would go to participants in a related beauty pageant. Contestants had to sign contracts r…
Referral network is denied business-league exemption
An organization applied for tax-exempt status as a business league under IRC § 501(c)(6). Its members met weekly to exchange business leads, only one member could represent each industry, and membersh…
Inactive business league loses tax-exempt status
The IRS revoked a business league's tax-exempt status under IRC § 501(c)(6) after determining that it had ceased operations and regular financial activity. The examination report states that a state a…
Lodging association loses exemption for member-specific services
The IRS revoked a lodging association's tax-exempt status under IRC § 501(c)(6). The association's principal activities included advertising member properties, inspecting those properties, processing …
Conservation organization's product sales are an unrelated business
A tax-exempt conservation organization sold redacted products through an online store, printed catalog, and unrelated retail outlets. The sales resembled those of commercial sellers, included products…
Shopping-center merchants association denied charitable status
A shopping-center merchants association collected assessments from tenants to market and promote the center, represent tenant interests, and conduct public events and merchant meetings. Its articles s…
Festival society denied charitable tax exemption
A membership society organized masked parades, festivals, balls, galas, and other events tied to local pirate history and Mardi Gras traditions. Although it raised money for local children and schools…
Mobile retreat bus fails charitable operational test
An organization operated mobile retreats using a converted bus that provided transportation, sleeping accommodations, meals, sightseeing, recreation, and some Bible lessons. Its main customer paid for…
Member funeral-benefit association denied charitable status
A mutual-benefit association charged members registration and per-death fees, then made prompt funeral-expense payments when a member or registered family member died. The payments were automatic, wen…
Inactive business league loses tax-exempt status
An organization recognized as a tax-exempt business league had stopped conducting activities and had no planned operations or regular financial activity. A state attorney general's investigation had r…
Condominium association denied charitable status
A nonprofit homeowners association applied for recognition as a charitable organization. It managed a condominium complex and collected monthly fees from condominium owners to pay common costs. The IR…
Inactive charity fails the operational test
A charitable organization had conducted fundraising through telemarketing and advertising sales. A state attorney general investigated indications that an officer or key employee used organization fun…
Failure to provide examination records ends exemption
A charitable organization did not respond to repeated IRS letters and telephone calls requesting financial records and information about its activities. Without that information, the organization did …
Missing records and private inurement end charitable exemption
The IRS revoked a charitable organization's exemption effective January 1, 2012. The organization did not provide records needed to verify its activities, receipts, expenditures, or continued operatio…
Public-facing business becomes the organization's primary activity
A section 501(c)(4) social welfare organization operated a public-facing business that generated 92.56 percent of its income. Although the organization made grants and provided some social welfare ben…
Inherited rental properties avoid UBIT and private-foundation excise taxes
A private foundation expected to inherit commercial rental properties through single-member limited liability companies and planned to use another disregarded LLC to manage them. The IRS ruled that qu…
Social club denied exemption for recurring oil and gas income
A hunting, fishing, shooting, and boating club sought recognition as a tax-exempt social club under IRC § 501(c)(7). The club regularly received most of its revenue from nonmember sources, including o…
IRS revokes charity status after personal expenses benefited its founder
The IRS revoked a charity's section 501(c)(3) status after an examination found repeated payments of personal expenses and other disbursements benefiting its founder. The organization used cash withdr…
IRS revokes motorcycle club's charitable exemption
A motorcycle club held an annual fundraiser and made donations to community charities, but much of its property and activities served members, families, and guests. The examination found member-only r…
Foundation's passive receipt of legal-fee receivables is not UBIT
A decedent's professional company held vested receivables for legal services completed before the decedent's death. After the company dissolved, the decedent's will directed its remaining property to …
IRS finds no prohibited inurement from a VEBA merger and asset transfer
A VEBA trust proposed absorbing two other VEBA trusts and receiving a one-time transfer from a collectively bargained retiree medical trust. The surviving trust would keep the former trusts in separat…
A VEBA termination amendment preserved its prior exemption
A tax-exempt voluntary employees' beneficiary association planned to amend its trust agreement, terminate, and transfer its assets to a section 115 trust that would fund retiree health benefits. The V…
A home-renovation organization was denied exemption
An organization proposed buying, renovating, and selling homes to lower-income buyers, while using a related real estate brokerage and construction company owned by members of its governing body. The …
Private-drive association denied social-welfare exemption
An unincorporated association of four homeowners applied for exemption under section 501(c)(4). It collected equal assessments to pay for snow plowing and other maintenance of their shared private dri…
Social club exemption revoked for public business activity
A long-exempt social club earned substantial receipts from nonmember events and also leased offices and parking spaces to members and nonmembers. It advertised itself as a public event venue, employed…
Inactive charity's exemption revoked
An organization had been recognized as tax-exempt under section 501(c)(3) since 1978. During an examination, the IRS found that it had discontinued operations and had no regular financial activity or …
IRS revoked a business incubator's exemption over commercial rentals
A nonprofit was formed to promote economic revitalization, create jobs for low- and moderate-income people, assist small businesses, and operate a business incubator. The IRS examination found that th…
Office condominium association denied business-league exemption
An office condominium association sought reinstatement of tax-exempt status as a business league under IRC § 501(c)(6). It maintained common property and paid shared expenses for the owners of units i…
Single-brand dealership association denied business-league exemption
An association limited membership to purchasing, finance, fleet, and related employees of dealerships selling one redacted brand. It held annual meetings to share purchasing practices, standardize pro…
Public charity recognized as a section 4945(f) exempt operating foundation
An organization already recognized as a section 501(c)(3) public charity asked to be recognized under section 4945(f). Based on the supplied information and the organization’s proposed operations, the…
IRS treats a large bargain-sale contribution as an unusual grant
A long-established public charity expected to acquire nonvoting corporate stock from three grantors in a bargain sale, paying part of the stock's value with a 20-year promissory note. The difference b…
IRS revokes charity accused of operating an illegal trust mill
An organization obtained IRC § 501(c)(3) status after representing that it would help seniors live independently through counseling, transportation, funding, and home-accessibility improvements. The I…
IRS revokes exemption of a property-holding fraternal organization
An organization recognized under IRC § 501(c)(10) held property and investment assets associated with another membership organization. It had only two officers or board members, no separate membership…
IRS revokes inactive charity that could not document current activities
A charity was originally recognized for Spanish-language education and training for child-care providers. During examination, it reported that the instructor had left the United States, the original t…
IRS revokes charity for private benefit, poor records, and unsupported activities
A charity was recognized to help victims of child sexual abuse and educate the public about its effects. The IRS found little reliable evidence that the organization actually conducted its claimed wor…
IRS denies exemption to law center tied to insiders' for-profit firm
A proposed public-interest law center planned to represent members of a redacted group in criminal, civil, immigration, and constitutional matters. Two of its three directors, a married couple, equall…
Stock-car racing organization denied section 501(c)(3) status
A nonprofit operated a stock-car racetrack, charged drivers and spectators, sold advertising and concessions, and paid cash prizes to race winners. The IRS found that its organizing document benefited…
Exempt status revoked for failure to provide examination records
The IRS repeatedly asked an exempt organization for financial, operational, and recordkeeping information needed to examine its Form 990-N filing period. Letters were sent to the organization and its …
Umpire association denied section 501(c)(3) exemption
An association trained baseball and softball umpires, assigned them to games and tournaments, collected some tournament and travel-game fees, and held a year-end banquet. The IRS found that the associ…
Business trust denied section 501(c)(3) exemption
A business trust sought section 501(c)(3) status for arrangements involving related companies, credit, debt, insurance, fictitious names, and purported tax-free financing. Its trust document authorize…
Historic lodging association loses section 501(c)(6) exemption
An association of historic lodging properties had been recognized as tax-exempt under section 501(c)(6). Its principal activities included advertising individual member properties, inspecting those pr…
Non-MSSP accountable care organization denied exemption
A tax-exempt health system formed an accountable care organization to integrate employed and independent physicians, measure performance, and negotiate incentive-based agreements with private payers. …
Social club denied exemption because of recurring royalty income
A hunting, fishing, shooting, and boating club sought reinstatement of exemption under section 501(c)(7). Although its membership and facilities served recreational purposes, most of its revenue came …
Motorcycle chapter denied social club exemption
A motorcycle owners' chapter spent most of its time on rides and social gatherings, but a sponsoring dealership and related brand organizations retained extensive control over its officers, members, c…
Medical cannabis collective denied charity status
A nonprofit corporation proposed to cultivate or obtain medical cannabis and deliver it to qualified patients who joined its collective. Its business plan also called for membership growth, advertisin…
Dog-breed parent club denied charity status
A parent club for a specific dog breed hosted four to six conformation shows each year and also maintained breed standards, a registry, health information, and educational materials. Dog shows produce…
Dance scholarship charity denied for private benefit
A nonprofit planned scholarships, camps, workshops, and other performing-arts programs for underserved girls. Its founder also owned a related for-profit dance company, and the nonprofit would award s…
Inactive small-business lender loses exemption
A nonprofit was formed to provide equity capital and loans to disadvantaged small businesses in low- and moderate-income neighborhoods. An IRS examination found that it had stopped making loans, condu…
Political advertising group denied social welfare exemption
A community organization sought exemption under section 501(c)(4) after spending all of its first-year expenditures on election mailers and radio advertisements that supported or opposed candidates. I…
Credit counseling organization loses exemption over commercial operations and private benefits
The IRS examined a nonprofit credit counseling organization whose main operation was a call center that enrolled and serviced consumers in debt management plans. The agency concluded that the organiza…
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.