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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Student-athlete NIL collective denied charity status for private benefit
A nonprofit proposed to raise funds and pay selected high-profile student-athletes at one school for name, image, and likeness services benefiting local and regional charities. The athletes would perf…
Lake property owners' litigation group denied charity status
An association of lake-area property owners sought § 501(c)(3) status while raising money to fund a lawsuit against nearby campground operations. The suit sought to stop alleged permit violations and …
Membership association was denied charity status because its social activities served a substantial nonexempt purpose
An ethnic membership association sought recognition as a charity under IRC § 501(c)(3). Its bylaws focused on cultural ties, mutual assistance, friendly relations, social connection, and unification a…
Organization received a final denial after it did not protest the proposed adverse determination
The IRS issued a final determination that an organization did not qualify for exemption under IRC § 501(c)(3). The final letter says the IRS had sent a proposed adverse determination explaining the fa…
Professional gardeners’ trade association was denied charity status
A membership organization of gardening and landscaping professionals applied for recognition under IRC § 501(c)(3). Its articles described it as a trade association and mutual-benefit corporation that…
Internet campaign for a discontinued product was denied social-club status
An organization conducted an Internet campaign seeking the return of a discontinued consumer product. It used emails, letters, phone calls, an online petition, a billboard, social media, and a one-tim…
Open video-game meetups were denied charity status because recreation was a substantial purpose
An organization ran weekly in-person and online video-game meetups that it described as safe spaces for marginalized groups. Its events were open to people of all ages and backgrounds, and it did not …
Blockchain standards coalition was denied charity status because it primarily benefited an industry
An organization sought IRC § 501(c)(3) status to develop and promote an international blockchain standard for representing industry items as non-fungible tokens. Its articles described an industry all…
Social dining group with a member loan fund was denied charity status
An unincorporated association met monthly in members’ homes to cook, entertain one another, socialize, and provide emotional support, with two restaurant gatherings each year. Members contributed a re…
Church lost exemption after ceasing religious activities and operating rental properties
A recognized church filed annual information returns reporting contributions, rental income, mortgaged properties, and outside-service expenses. During a church tax inquiry and examination, it did not…
Fundraiser for its founder’s heart transplant was denied charity status
An unincorporated association planned raffles, spaghetti dinners, and breakfasts to raise money for its founder’s heart transplant, food, and other expenses. Family and friends would organize the even…
Community foundation’s exceptionally large restricted donation qualified as an unusual grant
A community foundation expected an exceptionally large donation, more than one hundred times the donor’s usual support and many times the foundation’s average annual donations. The funds will create c…
Firefighter labor union was denied charity status because it served members’ employment interests
A local firefighter union applied for exemption under IRC § 501(c)(3). Its constitution and bylaws lacked both a purpose clause and a dissolution clause, so the IRS found that it failed the organizati…
Inactive land-holding charity lost exemption for conducting no charitable activity
A publicly supported organization had been inactive for multiple years. Its original directors faced health issues and pandemic restrictions, and its only current activity was maintaining donated parc…
Downtown merchant group denied charitable exemption for serving member businesses
An organization of downtown brick-and-mortar businesses applied for IRC § 501(c)(3) status. Its bylaws focused on promoting the downtown business district, merchant cooperation, community events, and …
Inactive church lost exemption after insider property transfer
An organization recognized as a church had conducted no recent religious activities and had no funds in its bank account during the examined year. Court records and the IRS examination also indicated …
Unresponsive supporting organization lost exemption for failing to provide records
A functionally integrated Type III supporting organization did not respond to repeated IRS requests for records needed to verify its continued qualification under IRC § 501(c)(3). The IRS mailed the e…
IRS denies 501(c)(3) status to a neighborhood association that is substantially social and recreational
A midtown neighborhood association applied for charity status under section 501(c)(3) using the short Form 1023-EZ. Its mission was to build community spirit and civic pride by running events like a H…
IRS denies 501(c)(3) status to a college-athlete NIL collective for serving private interests
An organization applied to be recognized as a tax-exempt charity under section 501(c)(3). Its business was to line up college athletes' name, image, and likeness (NIL) rights, then provide those NIL r…
IRS denies 501(c)(6) business-league status to a group promoting blockchain open-source software
A section 501(c)(6) business league is a tax-exempt association of people with a common business interest whose purpose is to improve conditions across a whole line of business, not to run a for-profi…
Members-only mutual benefit society denied 501(c)(3) charity status
A membership association applied for tax-exempt charity status under IRC § 501(c)(3) using the streamlined Form 1023-EZ. Membership was open to people of a particular national-origin descent who paid …
Business-referral networking chapter denied 501(c)(7) social club exemption
A membership organization applied to be recognized as a tax-exempt social club under IRC § 501(c)(7). Its sole activity was running weekly meetings and networking events where members exchange busines…
IRS denies 501(c)(3) exemption to a members-only mutual-aid association paying benefits for life events
This is a final IRS letter denying tax-exempt charity status under Section 501(c)(3) to a members-only mutual-aid association. The group's members each pay a monthly fee, and the group uses that money…
IRS denies 501(c)(3) exemption to a college-athlete NIL collective that pays student athletes
This is a final IRS letter denying tax-exempt charity status under Section 501(c)(3) to an organization that operates as a college-sports "name, image, and likeness" (NIL) collective. The group signed…
IRS denies 501(c)(3) exemption to a union bargaining organization serving its own members
This is a final IRS letter denying tax-exempt charity status under Section 501(c)(3) to an organization of union representatives. The group applied using the short Form 1023-EZ, attesting that it oper…
Foundation loans to a manager's own companies are self-dealing, private benefit, and jeopardizing investments
A private foundation, run solely by a married couple who were its only board members and officers, made many unsecured balloon loans totaling a large sum to two companies that one of the managers had …
IRS revokes an inactive nonprofit's 501(c)(3) status for failing the organizational and operational tests
This is a final IRS letter revoking a small nonprofit's tax exemption as a charity under Section 501(c)(3). On audit, the organization could not show it was doing any charitable work: it had lost its …
Letter 4038 (202502006): Denial of 501(c)(4) social-welfare exemption to a gated homeowners association operated for its members
This is a final IRS letter denying tax-exempt status as a social welfare organization under Section 501(c)(4). To qualify, a group must operate primarily to promote the common good and general welfare…
Letter 4038 (202501016): Denial of 501(c)(4) social-welfare exemption to a small homeowners association operated for its members' private benefit
This is a final IRS letter denying tax-exempt status as a social welfare organization under Section 501(c)(4). To qualify, a group must operate primarily to promote the common good and general welfare…
Letter 4038 (202501015): Denial of 501(c)(5) labor-organization exemption to a group that could not show it primarily serves employees
This is a final IRS letter denying tax-exempt status as a labor organization under Section 501(c)(5). To qualify, a group must primarily serve the interests of "labor," which the law reads as the inte…
Letter 6337 (202501014): Revocation of 501(c)(3) status for a dormant church that could not substantiate loan withdrawals, triggering excess-benefit tax
This is a final IRS letter revoking a small organization's 501(c)(3) tax exemption. To keep the exemption, a charity must be both organized and operated exclusively for exempt purposes and must keep r…
Letter 4038 (202501013): Exemption denied to a business-networking membership organization serving members' private interests
This is a final IRS letter denying tax-exempt status to an organization that applied under Section 501(c)(3). To qualify, a group must be organized and operated exclusively for exempt purposes such as…
Letter 6337 (202501012): Revocation of 501(c)(3) status for an inactive organization that failed to substantiate the operational and organizational tests
This is a final IRS letter revoking a charity's tax exemption. To keep 501(c)(3) status, an organization must be both organized and operated exclusively for exempt purposes (the organizational and ope…
NIL collective for college athletes denied 501(c)(3) for private benefit
An organization applied for 501(c)(3) charitable status built around a "name, image, and likeness" (NIL) collective: it paid college student-athletes at one university to use their NIL for work with l…
Gated homeowners association loses 501(c)(4) status for restricting the public
A homeowners association can qualify as a 501(c)(4) "social welfare" organization only if it serves a community in a way that benefits the general public, not just its own members. A long-running IRS …
Exemption automatically revoked for filing 990-N while over the $50,000 threshold
Small tax-exempt organizations with average gross receipts of $50,000 or less can meet their annual IRS filing duty with a short electronic notice, the Form 990-N "e-Postcard." Larger organizations mu…
Civil-rights and blockchain-art group denied 501(c)(3) exemption
A newly formed nonprofit applied for 501(c)(3) charitable status, describing a mission to defend citizens' constitutional and civil rights through legal, educational, and social activities, including …
Student-athlete NIL collective denied 501(c)(3) exemption for serving private interests
An organization applied for 501(c)(3) charitable status using the streamlined Form 1023-EZ. Its stated mission was to help a school's student athletes use their Name, Image and Likeness (NIL) rights b…
Two disregarded LLCs' education-and-workforce activities ruled charitable and educational
A 501(c)(3) public charity focused on connecting education to careers owns two single-member LLCs that are disregarded (treated as part of the charity) for tax purposes. It asked the IRS to confirm th…
A charity whose funds paid for casinos, mortgages, and personal expenses loses its 501(c)(3) exemption
The IRS revoked an organization's tax-exempt status under Code section 501(c)(3) on two grounds. First, it failed the operational test: the group could produce no records showing it conducted any exem…
A charity that stopped operating and kept no records has its 501(c)(3) exemption revoked
The IRS revoked a small organization's tax-exempt status under Code section 501(c)(3). The group had been recognized as a public charity, but an examination found it had stopped operating: the buildin…
Women's golf club denied section 501(c)(3) status
An organization of adult women golfers applied for recognition under section 501(c)(3). Its governing documents did not state a qualifying exempt purpose, and its activities consisted mainly of weekly…
Credit counseling business denied section 501(c)(3) status
An organization offered credit restoration, dispute resolution, monitoring, budgeting, debt assistance, and homebuyer services through enrollment and monthly-fee packages. Most of its revenue came fro…
Farmers' market denied section 501(c)(3) status
An organization operated a weekly market where local farmers, crafters, food vendors, and artists paid small fees to sell goods to the public. The organization provided the location, promotion, signag…
Burial-benefit association denied section 501(c)(3) status
A membership association collected fees to pay lump-sum burial benefits to beneficiaries named by its members. Membership was limited by ancestry and residence, but the organization imposed no financi…
Teachers' union denied section 501(c)(3) status
An association of certified teachers applied for recognition as a tax-exempt charity under section 501(c)(3). The association operates as a union, collects membership fees through payroll deductions, …
Cemetery denied section 501(c)(3) status
An organization that maintains a cemetery in a rural, economically depressed county applied for recognition under section 501(c)(3). It provides perpetual care without a separate fee but sells burial …
IRS revokes a scholarship charity's 501(c)(3) status for private inurement
This final IRS letter revokes the 501(c)(3) exemption of a small scholarship charity because its own money ended up paying its insiders' personal expenses. The organization had incorporated using gene…
IRS denies 501(c)(3) status to a recreational archery club
An organization applied for recognition as a charity under Section 501(c)(3). It operated an outdoor archery range, sold individual and family memberships, held public 3-D shoots, and scheduled team c…
IRS denies 501(c)(3) status to a downtown business association
A downtown and waterfront business association applied for recognition as a charity under Section 501(c)(3). Its members were local business owners and managers who organized events, decorated an unde…
Pension amendment increases liabilities but qualifies as reasonable and de minimis
A multiemployer pension plan had received a five-year extension for amortizing unfunded liabilities. Its terms imposed six additional months of benefit suspension when an early retiree returned to cov…
Private foundation lost exemption after five years without exempt activity
A nonoperating private foundation was examined after reporting no operational or financial activity for five years. Its president said the organization lacked funding and resources and expected a rela…
Employee discount-card group does not qualify as a business league
An organization of local employers applied for exemption as a business league under Section 501(c)(6). It collected annual dues and provided member employees with a digital card offering discounts fro…
Hunting-dog club denied section 501(c)(3) status
An organization applied for recognition as a section 501(c)(3) charity based on activities involving the training and testing of versatile hunting dogs. It offered member-only training days, equipment…
Cemetery organization denied section 501(c)(3) status
A nonprofit corporation applied for section 501(c)(3) status for cemetery activities that included selling burial plots, collecting maintenance fees, and maintaining a cemetery. It said the services b…
Member welfare and recreation group denied section 501(c)(3) status
An organization applied for section 501(c)(3) status while describing its mission as promoting member welfare, recreation, fellowship, and common interests. Its activities included a memorial run bene…
Cemetery operator denied section 501(c)(3) status
A nonprofit cemetery operator applied for recognition under section 501(c)(3). Its activities consisted of selling burial plots, digging graves, maintaining cemetery property, offering burial and crem…
Charity loses 501(c)(3) status after its funds benefited insiders
The IRS revoked a public charity's 501(c)(3) status after an examination found that its money and accounts benefited people with private interests in the organization. The charity and a related nonpro…
Charity loses exemption after bank records show personal spending
The IRS revoked a charity's 501(c)(3) status after it repeatedly failed to provide records or explain its activities during an examination. Financial records obtained through summonses showed that an …
Digital-asset rewards are taxable before a bankrupt platform freezes the account
A cash-method taxpayer received staking and other digital-asset rewards in an account before the platform froze customer accounts and filed for Chapter 11 bankruptcy. When credited, the rewards belong…
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.