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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Referral network served members rather than a line of business
A professional networking organization sought exemption as a business league under IRC § 501(c)(6). Its members came from different industries, met weekly to exchange referrals, and were limited to on…
Public golf fundraiser produced too much nonmember income
A membership organization sought exemption as a social club under IRC § 501(c)(7). It held an annual golf fundraiser open to members and the public, solicited public donations and sponsorships, and co…
Homeowners association primarily benefited private property owners
A homeowners association sought exemption as a social welfare organization under IRC § 501(c)(4). It maintained common areas and the front yards of private lots, funded those services through owner as…
IRS revokes 501(c)(3) status of a charity that ran a private poker club, for gaming as its primary activity and inurement to its director
The IRS revoked the tax-exempt charity status of an organization whose main activity was running a private, members-only poker club (daily poker tournaments, casino nights) that operated seven days a …
Gated common areas served homeowners rather than the public
A homeowners association sought exemption as a social welfare organization under IRC § 501(c)(4). It maintained lawns, a common driveway, and access areas for its members, funded entirely by membershi…
Labor representation primarily benefited union members
A labor union association sought recognition as a charity under IRC § 501(c)(3). It represented members in collective bargaining, grievances, workplace safety, and employment conditions. It also plann…
Expatriate social club did not serve charitable or educational purposes
An organization created a community for expatriates from the same homeland and sought exemption under IRC § 501(c)(3). It used member dues for happy hours, sports competitions, tickets, trips, and oth…
Dominoes club primarily served members' recreation
A hobby club sought recognition as a charity under IRC § 501(c)(3). Its members would socialize and play dominoes at activities closed to the public. The club expected to use its small budget for oper…
Rodeo organization had substantial recreational purposes
An organization that was already exempt under IRC § 501(c)(4) applied for recognition as a charity under IRC § 501(c)(3). Its main activity was planning, fundraising for, and conducting an annual comm…
Fundraising credits primarily benefited participating families
A booster club sought recognition as a charity under IRC § 501(c)(3) to support youth arts and athletics. Members volunteered at concession stands and received fundraising credits based on the amounts…
Dog training and trials were not exclusively educational
A dog club applied for recognition as an educational charity under IRC § 501(c)(3). It planned to offer paid dog-training sessions, clinics, seminars, and competitive dog trials, with the dogs as the …
Motorcycle club primarily served social and recreational purposes
A motorcycle club applied for recognition as a charity under IRC § 501(c)(3). Members paid dues for a clubhouse and utilities, met for motorcycle rides, held picnics, played horseshoes, and invited ba…
Condominium landscaping primarily benefited unit owners
A condominium homeowners association applied for recognition as a charity under IRC § 501(c)(3). It collected monthly dues to maintain landscaping and pay expenses for common property next to a public…
Merger transfer qualifies as an unusual grant
A publicly supported charity operating an equine-therapy and educational center planned to merge with its Type I supporting organization. The charity would survive and receive all of the supporting or…
Tax-services organization denied social-welfare exemption
A nonprofit sought exemption under IRC § 501(c)(4) for a membership-based tax-services operation that also planned taxpayer education and some free help for people facing hardship. Members paid an ini…
Military member-benefit group denied charitable exemption
A membership organization associated with a military organization sought exemption under IRC § 501(c)(3). It collected annual dues based on rank and used the money for members' birth, death, promotion…
Competitive gaming group denied charitable exemption
An organization promoting safer and more inclusive gaming spaces for marginalized genders sought exemption under IRC § 501(c)(3). Its principal activity was operating sponsored online tournaments fund…
Family reunion organization denied charitable exemption
A family organization sought exemption under IRC § 501(c)(3) for reunions, holiday gatherings, other family events, and financial support for elderly relatives. Its activities were restricted to famil…
Farmers'-market operator denied 501(c)(3) exemption for serving vendors' private interests
An organization that runs a farmers' market applied for tax-exempt status under Section 501(c)(3) using the short Form 1023-EZ. The IRS denied it. The group rents space from a park district, charges v…
Sole-proprietor cemetery denied 501(c)(3) status for serving its founder's private interests
A cemetery applied for tax-exempt status under Section 501(c)(3) as a religious organization, using the short Form 1023-EZ. The IRS denied it. In follow-up questions the applicant explained that its f…
Business-networking group denied 501(c)(6) status for performing particular services for sponsors
A group that runs business-networking events applied for tax-exempt status as a business league under Section 501(c)(6). The IRS denied it. The group holds free monthly networking events at local venu…
Fee-based payment service for lawyers denied 501(c)(3) status as a commercial activity
An organization applied for tax-exempt status under Section 501(c)(3) to run a service that helps law firms send and receive payments securely and in compliance with applicable rules. The IRS denied i…
Homeowners' association denied 501(c)(3) status; fails organizational and operational tests
A homeowners' association, organized as a mutual benefit corporation, applied for tax-exempt status under Section 501(c)(3) using the short Form 1023-EZ. The IRS denied it on both required tests. On t…
Community-festival organizer denied 501(c)(3) status for substantial social and recreational purpose
An organization that plans and runs community events applied for tax-exempt status under Section 501(c)(3). The IRS denied it. Its main activity is an annual summer town festival (live music, food tru…
Hunting-dog training club denied 501(c)(3) status; dog training is a substantial non-exempt purpose
A dog club applied for tax-exempt status under Section 501(c)(3). The IRS denied it. The club's purpose is to better a particular dog breed and to influence its breeding and training; it provides K9 e…
501(c)(3) status revoked after the organization ignored an audit and produced no records
The IRS revoked an organization's existing 501(c)(3) tax-exempt status. The organization had been recognized as exempt after filing a Form 1023-EZ, but the IRS later selected it for audit to confirm i…
Fundraiser for director's grandchild denied exemption
An organization sought charitable status to collect donations for the medical bills, living expenses, and unpaid utilities of one severely injured person. That person was the grandchild of the organiz…
Trade-promotion group denied charitable exemption
An organization sought charitable status for promoting companies from one country and helping them sell products and services in another market. It ran an annual exhibition, roadshows, and seminars, a…
Member-benefit association denied charitable exemption
An unincorporated association sought charitable status while providing financial benefits to its members and their immediate families. Its programs included medical and disaster benevolence, transport…
Paid umpire association denied charitable exemption
An umpire association sought charitable status for assigning officials to matches and training its members in the sport's rules. Leagues and tournaments paid the umpires for their work, and most membe…
Family genealogy group denied charitable exemption
A family association sought charitable status to build its family tree, purchase DNA tests through membership fees, locate relatives, research ancestral communities, and organize family travel and gat…
Local-business promotion group denied charitable exemption
A group organized to support local businesses held pop-up shopping events, spotlighted a business each month, arranged restaurant meetings, and conducted ribbon cuttings. The community was not designa…
Public golf course denied social-club exemption
A nonprofit operated an 18-hole public golf course, bar, and restaurant and rented its facilities for private events. Although it had members, the facilities were open to the general public, membershi…
Threat-response service group denied business-league exemption
An organization formed to share threat information among members planned conferences, a threat database, encrypted collaboration tools, continuous monitoring, training, consulting, risk assessments, a…
Condominium association denied social-welfare exemption
A condominium association maintained one building's roof, siding, plumbing, appliances, fencing, patios, landscaping, sidewalks, and alleyway. Unit owners were its only members and supplied all of its…
Community festival group denied charitable exemption
An organization applied for recognition as a charity under IRC § 501(c)(3). Its main activity was an annual community festival with entertainment, vendors, rides, games, contests, a car show, and a pa…
Artist sales space denied charitable exemption
An organization sought recognition as a charity under IRC § 501(c)(3) for operating an affordable retail space where artists could display and sell their work. Artists kept most of each sale and the o…
Homeowners association denied charitable exemption
A homeowners association applied for exemption as a charity under IRC § 501(c)(3). It maintained resident-only common property, operated a sewage collection and treatment system for a subdivision, col…
Democracy-promotion organization denied business-league exemption
An organization applied for exemption as a business league under IRC § 501(c)(6). Its mission was to strengthen democracy in emerging and fragile democracies through independent media, public-opinion …
Fireworks and community-events business denied charitable exemption
An organization applied for exemption as a charity under IRC § 501(c)(3). It organized community gatherings with music, vendors, entertainment, and fireworks, sold professional fireworks displays for …
Missionary vacations on a catamaran denied charitable exemption
An organization used a catamaran sailboat to give pastors, missionaries, and their families free vacations after service in challenging mission fields. Guests could snorkel, swim, fish, explore island…
Automobile club denied charitable exemption
An automobile club applied for exemption under IRC § 501(c)(3), describing education about a particular vehicle brand, an annual car show and swap meet, monthly planning meetings, and quarterly meetup…
Member-controlled farmers’ market denied charitable exemption
A member-controlled farmers’ market applied for exemption under IRC § 501(c)(3). Its articles did not limit its purposes to exempt purposes, and its primary activity was operating a weekly market wher…
Sports officials association denied charitable exemption
A membership association for sports officials applied for exemption under IRC § 501(c)(3). It trained officials and participated in clinics and charitable events, but a significant part of its work co…
Social dinner club denied charitable exemption
A membership club applied for exemption under IRC § 501(c)(3), describing its charitable purpose as promoting hospitality and community involvement. Its principal activity was a series of catered dinn…
Room-rental operation denied reinstatement of charitable exemption
An organization sought reinstatement of its IRC § 501(c)(3) exemption after automatic revocation for failing to file required annual returns or notices. It initially described plans to rehabilitate pe…
Common-area maintenance association denied charitable exemption
An association applied for exemption under IRC § 501(c)(3) to maintain the common areas of a development. It charged property owners according to their square footage and used the fees for landscaping…
Member water cooperative denied charitable exemption
A utility district applied for exemption under IRC § 501(c)(3) for providing water service to landowners in a particular area. Membership followed ownership of the land, the number of shares was limit…
Tourism promoter denied charitable exemption
An organization applied for exemption under IRC § 501(c)(3) to promote tourism and local businesses in economically distressed areas. It planned public motorcycle, automotive, and watersports events, …
Employee bargaining association denied charitable exemption
An unincorporated employee association sought exemption under IRC § 501(c)(3) after its prior IRC § 501(c)(5) group exemption was automatically revoked. Its primary activities were negotiating and enf…
Charity loses exemption over gaming operations and private benefit
The IRS revoked a charity's IRC § 501(c)(3) exemption after examining its fundraising, spending, governance, and use of assets. The organization raised substantially all of its revenue through raffles…
Organization loses exemption for political campaign intervention
The IRS revoked an organization's IRC § 501(c)(3) exemption after finding repeated political campaign intervention. The organization sent mass communications to residents before local elections that p…
Organization loses exemption over insider loans and private benefits
The IRS revoked an organization's IRC § 501(c)(3) exemption after finding substantial private benefit to its officers and inadequate records. The organization reported loans receivable from its marrie…
Private foundation may divide assets among family branches
A family private foundation proposed transferring more than 25 percent of its assets to two newly formed private foundations after directors from different family branches disagreed about programs, di…
Farmers' market denied charity status for vendor benefit and commercial activity
The IRS denied IRC § 501(c)(3) recognition to a nonprofit farmers' market that provided vendors a place to sell products, promoted the market, and covered shared operating expenses. The organization's…
Horse-show association denied charity status for recreational purpose
The IRS denied IRC § 501(c)(3) recognition to a state horse-breed association affiliated with a national section 501(c)(5) organization. The association's main activities were hosting breed-approved h…
Employee aid fund denied charity status for private benefit
The IRS denied IRC § 501(c)(3) recognition to a fund created to assist employees of one organization and its affiliates during disasters and other financial hardships. Only those employees and their f…
Member bereavement fund denied charity status for private benefit
The IRS denied IRC § 501(c)(3) recognition to a membership organization that pooled member payments to provide bereavement benefits. Eligibility depended on ancestry or family connection, members paid…
Dog-training club denied charity status because dogs were the primary trainees
The IRS denied IRC § 501(c)(3) recognition to a membership organization that conducted dog training, seminars, and competitive event trials for members and their dogs. Members paid a monthly fee, acti…
Farmers' market denied charity status despite SNAP and WIC programs
The IRS denied IRC § 501(c)(3) recognition to a weekly farmers' market whose vendors sold food and other products. The market participated in SNAP and WIC, offered a SNAP matching program, and perform…
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.