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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Family-descendant scholarship fund denied charity status
The IRS denied IRC § 501(c)(3) recognition to an organization that provided scholarships only to descendants of one family. Applicants also had to register for and attend the family reunion and be enr…
Church auxiliary is excused from filing Form 990
An IRC § 501(c)(3) organization asked to be exempt from the annual Form 990 filing requirement. Based on the information submitted, the IRS classified it as an integrated auxiliary of a church under T…
Business membership group denied charity status despite civic projects
The IRS denied IRC § 501(c)(3) recognition to a business membership organization that promoted local businesses, coordinated marketing, sought more customer foot traffic, and advocated for business-co…
Farmers market denied charitable exemption
A farmers market applied for exemption under IRC § 501(c)(3), saying it promoted health and wellness through local food access and education. The market accepted nutrition-assistance benefits, hosted …
Member burial-benefit organization denied exemption
An organization applied for tax-exempt status under IRC § 501(c)(3) to provide emotional support and pay funeral and burial expenses when a member or a member's family experienced a death. It paid fun…
Recreational pickleball organization denied exemption
An organization applied for exemption under IRC § 501(c)(3) to maintain community courts and offer pickleball open play, beginner clinics, tournaments, leagues, and special events. Participation was o…
Adult recreational soccer league denied exemption
An adult soccer league applied for exemption under IRC § 501(c)(3). It charged local teams registration fees and used the money to secure fields, referees, and other items needed for recreational game…
Employee social association denied exemption
A voluntary employee association applied for exemption under IRC § 501(c)(3). It organized bowling, softball, and cornhole tournaments, employee appreciation days, and picnics or parties for members' …
Artist sales festival denied exemption
An organization applied for exemption under IRC § 501(c)(3) for an annual fine arts and crafts show. Artists chosen through a jury process paid booth fees, set their own prices, handled their own sale…
Commercial manufacturer hiring abuse survivors denied exemption
A for-profit manufacturer and retailer applied for exemption under IRC § 501(c)(3). It hired women from abusive situations, paid above the federal minimum wage, and gave employees flexibility for appo…
Church auxiliary excused from filing Form 990
A tax-exempt organization asked to be excused from filing annual Form 990 returns. The IRS determined from the submitted information that the organization qualified as an integrated auxiliary of a chu…
Renewable energy and waste organization denied exemption
An organization sought recognition as a tax-exempt charity for activities centered on constructing and operating a facility that would convert solid waste into energy and marketable by-products. Durin…
Shareholder water company denied charitable exemption
A nonprofit water distribution company sought recognition as a charity under IRC § 501(c)(3). Property owners in its service area contributed water rights, received proportional shares, and paid charg…
Foreign charitable grants receive favorable excise tax rulings
A private foundation proposed grants to two foreign charitable organizations that would independently select secondary grantees for projects serving disadvantaged elderly people, children, teenagers, …
Beef-breed association denied charitable tax exemption
An international association of national beef-breed organizations applied for recognition under IRC § 501(c)(3). Its stated purposes included promoting the breed and its products, exchanging technical…
Single-company financial sales group denied business league exemption
An association whose members all sold financial products for one for-profit company applied for exemption as a business league under IRC § 501(c)(6). The group trained and developed the company's sale…
Commercial condominium association denied social welfare exemption
A mutual benefit corporation for a single commercial condominium building applied for exemption under IRC § 501(c)(4). Its members, mostly for-profit businesses, paid dues and assessments for the land…
Private road maintenance association denied charitable exemption
A membership association that maintained private gravel roads in a residential development applied for exemption under IRC § 501(c)(3), describing its work as testing for public safety. Lot owners pai…
Youth travel baseball team denied social club exemption
A nonprofit operating a travel baseball team for players age 12 or younger applied for social club exemption under IRC § 501(c)(7). The team practiced at a donated school field and used its funds for …
Open source software organization denied charitable exemption
An organization promoting open source collaboration, standards, software, certifications, and public digital infrastructure applied for exemption under IRC § 501(c)(3). It planned to make software fre…
Family-only scholarship organization denied tax-exempt status
An organization applied for recognition as a tax-exempt charity under IRC § 501(c)(3). It planned to preserve one family's legacy by awarding scholarships only to descendants of that family, and famil…
Fraternal lodge lost exemption because it lacked a member-benefit program and conducted substantial public business
A subordinate fraternal lodge operated a club with gaming, food, beverage, fee, and other revenue. The lodge told the IRS that it did not provide life, sick, accident, or similar benefits to members, …
Charity faced revocation after failing to substantiate its exempt operations
The IRS proposed to revoke an organization's recognition under IRC § 501(c)(3) after an examination of its Form 990-EZ. The organization provided some records and received several extensions, but the …
Condominium association denied social welfare exemption
A condominium homeowners association applied for exemption as a social welfare organization under IRC § 501(c)(4). It collected assessments to maintain the condominium building and restricted its faci…
IRS revoked a church's exemption after commercial rentals became its primary activity
The IRS revoked an organization's section 501(c)(3) status after concluding that its commercial equipment rental business had become its primary activity. The organization said its religious and commu…
IRS revoked a foundation that used fundraising to pay members' private expenses
The IRS revoked a private foundation's section 501(c)(3) status because its fundraising primarily benefited participating families and a related for-profit youth athletics program. Families received f…
IRS revoked exemption after a founder used organization funds for personal expenses
The IRS revoked an organization's section 501(c)(3) status after finding that its founder and chief executive received substantial private benefits. Bank and mortgage records showed unsubstantiated pa…
Homeowners association denied social welfare exemption
A homeowners association applied for exemption as a social welfare organization under IRC § 501(c)(4). It collected annual dues to insure and maintain common areas, provide utilities, and perform land…
Fundraiser for one medical patient denied charity status
An organization applied for recognition as a charity after forming to raise money for one named person and that person's parents following a heart transplant, hospitalization, complications, and lost …
Church-affiliated school exempted from Form 990 filing
An educational organization operating below the college level asked to be excused from filing Form 990. Based on the submitted information, the IRS classified it as a school with a general academic pr…
IRS revoked exemption because bingo operations became the primary activity
The IRS revoked an organization's section 501(c)(3) status because operating bingo for another exempt organization became its primary activity. The organization received nearly all of its income from …
501(c)(3) revoked for failing to file Form 990 for three years and conducting no exempt activities
The IRS revoked an organization's 501(c)(3) tax exemption for two independent reasons. First, on examination the IRS found the organization normally had more than $50,000 in gross receipts (its holdin…
Governmental affiliate excused from filing Form 990
A tax-exempt organization asked to be excused from filing annual Form 990 information returns. The IRS determined that the organization qualifies as a governmental unit or an affiliate of a government…
Church auxiliary excused from filing Form 990
A section 501(c)(3) organization asked to be exempt from filing annual Form 990 information returns. The IRS determined that it qualifies as an integrated auxiliary of a church. Treasury Regulation se…
One-time restructuring transfer treated as unusual grant
A publicly supported organization expected to receive most of the net assets of an affiliated section 501(c)(4) organization as part of a restructuring and merger. The transferor was not disinterested…
Member benefit organization denied section 501(c)(3) status
An organization formed by employees and volunteers of a local government agency collected dues to provide benefits to members during hardships and celebratory life events. Benefits included assistance…
Religious recovery home denied section 501(d) status
An organization planned to operate a religious residential recovery home for people recovering from substance abuse. Although its program included prayer, Bible reading, church attendance, counseling,…
Member funeral benefit organization denied section 501(c)(3) status
A membership organization collected membership and registration fees to provide cash, material, and spiritual support when a member or a member's immediate family member died. The IRS concluded that t…
Pharmaceutical consulting organization denied section 501(c)(3) status
An organization proposed to provide paid consulting services to pharmaceutical companies concerning pediatric skin diseases and donate the net proceeds to exempt organizations supporting research and …
Carbon-free energy business denied section 501(c)(3) status
An organization planned to design, build, own, and operate carbon-free electrical generation facilities, initially using solar panels and battery storage. It expected to earn fees for installed equipm…
Veterans' public restaurant and bar denied section 501(c)(3) status
A veterans' organization operated a restaurant and bar open to the general public every day, with prices comparable to other restaurants. It also raised funds and provided assistance for veterans, and…
Exemption revoked for inadequate records, nonresponse, and private benefit
The IRS revoked an organization's section 501(c)(3) exemption after it failed to substantiate its activities, provide complete financial records, or respond to repeated information requests. The limit…
Large construction grant recognized as an unusual grant
A publicly supported charity expected a large, unexpected cash grant from a grantor with no prior connection to the organization. The charity planned to use the installments for a playground, basketba…
Exemption revoked for inadequate records and unsubstantiated operations
The IRS revoked an organization's section 501(c)(3) exemption because it did not prove that it operated exclusively for scientific, educational, charitable, or other exempt purposes. During the examin…
Church-affiliated organization excused from filing Form 990
A section 501(c)(3) organization asked the IRS to excuse it from filing annual Form 990 information returns. Based on the submitted information, the IRS classified it as an organization affiliated wit…
Fraternal-beneficiary exemption denied for lack of a lodge system
A membership organization sought exemption as a fraternal beneficiary society under section 501(c)(8). Its primary activity was paying burial or repatriation costs and related death benefits for membe…
Hospital exemption revoked for section 501(r) failures
The IRS revoked a hospital authority's section 501(c)(3) exemption after examining its compliance with the Affordable Care Act's community-health requirements. The hospital used a shared community hea…
Dog-genetics organization denied exemption for private benefit
An organization sought section 501(c)(3) exemption to collect, store, and distribute frozen semen from a particular dog breed and to support related education and research. Its sole member was a secti…
Basketball-officials association denied section 501(c)(3) status
A membership association of basketball officials sought section 501(c)(3) exemption as an organization fostering amateur sports. Its main activity was contracting with school districts and assigning p…
Member art gallery denied exemption for private benefit
An arts organization sought section 501(c)(3) exemption for public classes, exhibits, festivals, artist support, and related programming. It also operated a gift shop where member artists paid monthly…
Ministry lost exemption after failing to substantiate charitable activity and allowing insider benefit
A religious organization said it would conduct online ministry, Christian programs, community assistance, and promotional activities. During the examination, it acknowledged that it had no website, di…
Research charity lost exemption after failing to document its activities, finances, and use of funds
A charity formed to conduct scientific research reported that it also offered youth basketball, tennis, and swimming programs and employed a foreign worker to research a camera’s capabilities. Its web…
Technology-business accelerator denied exemption for private benefit
An organization sought section 501(c)(3) exemption for an accelerator, conference, networking events, directory, and other programs serving underrepresented owners of small technology businesses. Its …
Educational organization lost exemption for private benefit and commercial activity
An educational organization offered fee-based courses, workshops, seminars, and online materials while contracting with related for-profit businesses for teaching services. The IRS examination found t…
Organization lost exemption for serving founder's private interests
An organization had once operated as a church but reported little or no activity after those operations ceased. Its representatives told the IRS that the organization's bank account had been used as a…
Charity loses exemption for unproven activities, poor records, and private benefit concerns
The IRS revoked a charity's § 501(c)(3) status after it failed to substantiate that its activities primarily served exempt purposes. The organization had one officer and director, provided only vague …
Property-owners association denied charity status
A membership organization of property owners applied for recognition under § 501(c)(3). Its stated purposes included furthering owners' interests, enforcing property restrictions, managing common area…
Dog club denied social-club exemption because most income came from nonmembers
A licensed dog club applied for exemption as a social and recreational club under § 501(c)(7). It held dog shows, raffles, member meetings, public education programs, and occasional charitable activit…
Automobile club denied charity status because recreation was a substantial purpose
An automobile owners' and enthusiasts' club applied for exemption under § 501(c)(3). It held car and motorcycle shows, picnics, parade and rodeo appearances, and other events for members and the publi…
Child-recovery charity lost exemption after substantial insider transfers and personal spending
A charity used volunteers to help locate and recover missing or exploited children, including work under a contract with a rehabilitation center. After that contract ended, the organization’s reported…
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.