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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Rural cemetery denied section 501(c)(3) status
A nonprofit operating a small rural cemetery applied for section 501(c)(3) recognition. Its governing document was incomplete because it lacked signatures from at least two authorized individuals, and…
Private foundation loses exemption for inactivity and insider-controlled assets
The IRS revoked a private foundation's 501(c)(3) status after finding that its purpose and operations had shifted away from the charitable program described in its exemption application. The foundatio…
Individually owned LLC denied section 501(c)(3) status
A single-member limited liability company applied for section 501(c)(3) recognition while proposing a food bank and a free senior center for low-income people. Its articles stated no exempt purpose, c…
Dog performance club denied section 501(c)(3) status
A membership-based dog performance club applied for section 501(c)(3) recognition as an educational organization. It conducted sanctioned agility, obedience, tracking, scent work, and other trials, ch…
Rural tourism organization denied section 501(c)(3) status
An organization sought section 501(c)(3) status for programs intended to empower rural communities through tourism, business training, grants, education, and cultural preservation. Its current activit…
Community pickleball club denied section 501(c)(3) status
A community pickleball club applied for section 501(c)(3) recognition while describing its mission as providing healthy, recreational, competitive, and social activity and growing the sport locally. A…
Running and yoga group denied section 501(c)(3) status
An organization applied for section 501(c)(3) status to promote physical fitness and healthy lifestyles among people in the restaurant and service communities. Its activities consisted mainly of runni…
Single-owner farm denied section 501(c)(5) status
A single-owner limited liability company sought exemption as an agricultural organization under section 501(c)(5). It operated a farm on property owned by its president and the president's spouse, gre…
Business networking group denied 501(c)(3) for member private benefit
A membership organization applied for 501(c)(3) status to help local startups and veteran-owned businesses through networking, education, referrals, discounts, promotional events, and grants for worki…
Religious loss-sharing plans denied 501(c)(3) as private insurance-like activity
A religiously affiliated organization applied for 501(c)(3) status while operating two loss-sharing programs for members' property and vehicles. Participants enrolled property, paid assessments based …
Youth-golf fundraiser denied 501(c)(7) social-club status
An organization formed to raise money for youth golf programs applied for exemption as a 501(c)(7) social club. It planned to buy equipment for children, hold camps and events, and support golf progra…
Fundraising charity loses exemption after founder diverted revenue for personal use
The IRS revoked a fundraising charity's 501(c)(3) status after an examination found that its founder and sole active officer controlled its operations and used charity revenue for personal expenses. T…
Purported church loses exemption for founder inurement and unsubstantiated activities
The IRS revoked the 501(c)(3) status of an organization that claimed to operate as a church. The organization did not substantiate regular religious services, a regular congregation, an established pl…
A large one-time grant to a community nonprofit is treated as an "unusual grant" that will not cost it public-charity status
A nonprofit that maintains parkland and runs community programs for residents of a large affordable-housing project asked the IRS to treat a big incoming grant as an "unusual grant." To keep public-ch…
Exemption denial became final after no protest
An organization applied for recognition as tax-exempt under section 501(c)(3). The IRS had sent a proposed adverse determination explaining the facts, law, and basis for denial, but the organization d…
Residents' group denied 501(c)(3) for benefiting a facility's staff
A residents' group at a senior living facility applied to be recognized as a tax-exempt charity under Section 501(c)(3) using the streamlined Form 1023-EZ. Its two main activities were paying higher-e…
Members' association denied 501(c)(3) for member home-downpayment loans and tutoring
An unincorporated members' association applied to be recognized as a tax-exempt charity under Section 501(c)(3) using the streamlined Form 1023-EZ. Its two activities were pooling money to give member…
Parade club denied 501(c)(7) social club status over nonmember bingo income
A membership organization that stages an annual parade and related member social events applied to be recognized as a tax-exempt social club under Section 501(c)(7). Its main source of money was bingo…
501(c)(3) supporting organization's exemption revoked for inactivity
A charity that had been recognized as a tax-exempt "supporting organization" (a Section 509(a)(3) group that exists to support a specific public charity) had its exemption revoked. To keep 501(c)(3) s…
Business-promotion group denied charitable status
An organization applied for section 501(c)(3) status to unite local businesses, industries, and civic organizations, promote trade, and conduct community events. Its activities included membership mee…
IRS revokes a fraternal society's 501(c)(8) exemption for not responding or keeping records
The IRS revoked the tax-exempt status of an organization that had been recognized as a fraternal beneficiary society under IRC Section 501(c)(8) through a group ruling. During an examination, the orga…
IRS revokes an inactive supporting organization's 501(c)(3) status
The IRS revoked the tax-exempt status of an organization that had been recognized as a public charity under IRC Section 509(a)(3), specifically a Type III non-functionally integrated supporting organi…
IRS denies 501(c)(3) status to a class-reunion organization
The IRS denied tax-exempt status under IRC Section 501(c)(3) to an organization formed to plan and hold class reunions and small gatherings for the members of a graduating class. To qualify as a chari…
IRS revokes exemption of a charity that stopped providing dialysis and now only rents its building
The IRS revoked the 501(c)(3) exemption of an organization that had originally been recognized as a charity because it promised to provide dialysis services and medical equipment at no cost to a rural…
IRS revokes a radio broadcaster's 501(c)(3) for inactivity and inurement to its officers
The IRS revoked the tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity to run noncommercial educational radio broadcasting. Two problems drove the revocation. …
Employee social organization denied exemption
An employee activity organization sought recognition as a charitable organization under section 501(c)(3). It sold coffee and snacks slightly above cost and used fundraising proceeds to subsidize holi…
Condominium association denied exemption
A condominium owners' association sought exemption as a social welfare organization under section 501(c)(4). It used member dues and assessments to maintain shared building systems, gated parking, sec…
Member benefit pool denied exemption
An organization sought charitable exemption under section 501(c)(3) and stated a purpose of helping poor, hungry, homeless, and underprivileged people. Its primary current activity, however, was colle…
Family private-banking organization denied exemption
An organization sought exemption under section 501(c)(3) for activities it described as processing family transactions and providing private banking to identify one family's birthright and heritage. P…
College athlete speaker program denied exemption
An organization raised donations to pay college athletes to give free motivational presentations at schools and community events. It contracted with a for-profit logistics company whose president also…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better t…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better t…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better t…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better t…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better t…
Local business group denied 501(c)(3) status for serving members' private interests
A local business group applied for recognition as a tax-exempt educational organization under Section 501(c)(3). It offered networking events, professional-development programs, online listings, socia…
Cattle-breed association denied 501(c)(3) status because member sales served private interests
An association of cattle owners and breeders applied for recognition under Section 501(c)(3). It held an annual show, meeting, banquet, and member sale, advertised members' cattle, and helped buyers l…
Winery association denied 501(c)(3) status because promotion served member businesses
A regional winery association applied for recognition as an educational organization under Section 501(c)(3). It promoted member wineries through signs, brochures, maps, a website that directed consum…
Adult social club denied 501(c)(3) status because recreation was a substantial purpose
An adult social club applied for recognition under Section 501(c)(3), then asked to change its application to Section 501(c)(7). Its activities included dinners, plays, movies, picnics, winery trips, …
Health-services organization lost exemption for private benefit and commercial activity
A health-services organization recognized under Section 501(c)(3) was examined after it shifted from its stated charitable, educational, and scientific purposes to providing paid services. The IRS fou…
Event organization lost exemption after failing the educational and recordkeeping tests
An organization recognized under Section 501(c)(3) primarily ran two annual public events, including one focused on commercial participants, and funded itself with admission revenue. It also described…
Business-referral networking club denied 501(c)(6) status
A networking club applied to be recognized as a tax-exempt business league under Section 501(c)(6). Its members are business professionals who meet weekly to swap referrals ("leads"), give short comme…
Members' mutual death-benefit fund denied 501(c)(3) status
A membership organization applied for 501(c)(3) charitable status. Its main activity is pooling premiums paid by members and giving cash to any member who recently loses a close family member (a spous…
501(c)(3) status revoked for private inurement after directors routed donations to personal accounts
The IRS audited a small charity and found that its directors were using the organization to enrich themselves. The organization solicited donations online under its own name and Employer Identificatio…
Green-hydrogen industry alliance denied 501(c)(3) status
An organization formed to advance clean ("green") hydrogen applied for 501(c)(3) charitable status. It raises public awareness of hydrogen as a zero-emission energy source, supports green-energy polic…
501(c)(3) exemption revoked after the organization stopped responding to IRS record requests
The IRS audited a 501(c)(3) organization and asked, repeatedly, for the records that every exempt organization must keep and produce: books showing its receipts, expenditures, and activities. The orga…
Anti-censorship web-tunneling developer denied 501(c)(3) status
An organization that writes software to defeat internet censorship applied for 501(c)(3) charitable status. Its technology lets users reach websites blocked in certain countries through a secure tunne…
Local farmers' market denied 501(c)(6) business-league status
An organization that runs a local farmers' market applied to be recognized as a tax-exempt business league under Section 501(c)(6). It rents space to local farmers and producers (its "vendors," who ar…
IRS denies 501(c)(3) status to a charity built around paying student athletes for their name, image, and likeness
An organization set up as a Type I supporting organization of a public charity applied for 501(c)(3) status. Its function was to receive donations and coordinate arrangements in which partner charitie…
IRS denies 501(c)(3) status to a member group paying death benefits and scholarships to members' families
An organization applied for 501(c)(3) charitable status using the streamlined Form 1023-EZ. It collected monthly dues from members and, in return, paid death benefits to members' families and one-time…
IRS revokes a private school's 501(c)(3) exemption for failing the operational and recordkeeping tests
This is a final IRS revocation letter (Letter 6337) ending a private religious school's tax-exempt status under § 501(c)(3), along with the audit report (Form 886-A) that explains why. The school had …
IRS denies 501(c)(3) status to a collector-car hobby club
The IRS denied tax-exempt status under IRC Section 501(c)(3) to a hobby club for owners and enthusiasts of a particular vintage automobile. The club described itself as a registry and social network s…
IRS revokes a 501(c)(3) organization's exemption for failing to respond to an audit
The IRS revoked the tax-exempt status of an organization that had been recognized as a public charity under Section 501(c)(3). Exempt organizations must keep records and let the IRS examine their rece…
IRS denies 501(c)(3) status to a fireworks-display organization
The IRS denied tax-exempt status under IRC Section 501(c)(3) to an organization that describes its mission as promoting "fireworks fun and safety" through education, training, hands-on experience, and…
IRS revokes 501(c)(8) status of a fraternal society that stopped responding
The IRS revoked the tax-exempt status of a fraternal beneficiary society that had been exempt under Section 501(c)(8). To keep that status, a group must be a fraternal organization operated under the …
IRS revokes 501(c)(3) status of a charity that stopped responding and kept no records
The IRS revoked a public charity's tax-exempt status because it went dark during an audit. The organization had been recognized under Section 501(c)(3) with public charity status under Section 170(b)(…
IRS revokes 501(c)(3) status of an inactive Type III supporting organization
The IRS revoked a nonprofit's tax-exempt status. The organization had been recognized as a Section 509(a)(3) supporting organization, a public charity that exists to support another named charity. On …
501(c)(3) exemption revoked for failure to produce records
The IRS revoked a public charity's tax-exempt status. The organization was selected for examination, but it never answered the IRS's Information Document Request, its officers' phone numbers appeared …
Recreational adult golf league denied 501(c)(3) status
A women's nine-hole golf league applied to be recognized as a tax-exempt charity under Section 501(c)(3) using the streamlined Form 1023-EZ. The group plays golf weekly at a local course in warmer mon…
501(c)(3) exemption revoked for failure to keep and produce records
The IRS revoked a public charity's tax-exempt status. During an audit of the group's Form 990, the IRS repeatedly asked for the organization's books, bank statements, contracts, meeting minutes, and o…
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.