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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Organization denied social club exemption
A nonprofit organization applied for exemption as a social club under Section 501(c)(7). Its principal activities included public bingo, food service, fundraising events, and renting its hall to membe…
AI competition organization denied charitable exemption
An organization formed to run open artificial-intelligence programming competitions applied for exemption under Section 501(c)(3). For-profit technology companies hosted and supported the competitions…
Dog training club denied charitable exemption
A volunteer dog club applied for exemption under Section 501(c)(3). It conducted public hunt tests and trials, offered training and seminars, held club meetings, and stated that its activities served …
Software user group denied business league exemption
An organization sought business league exemption for a user group limited to businesses in one industry that licensed a particular software product. Its activities promoted that product through traini…
Dog training organization lost its charitable exemption
An organization that had previously been exempt as a social club was later reinstated as a Section 501(c)(3) public charity. It conducted training classes, agility practice matches, membership meeting…
Member bereavement fund was denied charitable exemption
An organization applied for Section 501(c)(3) status to organize contributions and provide financial, emotional, spiritual, and social support when members or their families experienced a death. Its b…
IRS revoked a charity's exemption for personal expenses and inadequate records
The IRS revoked a charity's Section 501(c)(3) exemption after examining its finances and recordkeeping. The organization described itself as providing food, material aid, basic services, Bible studies…
Matchmaking and social-events organization was denied charitable exemption
An organization applied for Section 501(c)(3) status to connect members of a religious community through an online matchmaking service, paid in-person events, social media content, and giveaways. It a…
Organization failed the public-support test and was classified as a private foundation
An organization remained exempt under Section 501(c)(3), but the IRS made a final adverse determination that it did not qualify as a public charity under Section 509(a)(2). The organization had not sh…
For-profit logging company was denied agricultural-organization exemption
A logging company applied for exemption as an agricultural or horticultural organization under Section 501(c)(5). Its operating agreement allocated taxable income and cash flow to its sole member and …
Angel-investing group was denied business-league exemption
A membership organization sought Section 501(c)(6) exemption for activities promoting venture capital and angel investing and increasing participation in that ecosystem. It identified early-stage tech…
Cemetery denied exemption for nonexempt activity and private interests
An organization applied for IRC § 501(c)(3) status to maintain a public cemetery and sell burial plots. It reported a small number of plot sales each year but did not show that the cemetery had histor…
Supporting organization revoked for lacking required ties and distributions
An organization claimed exemption as a Type III non-functionally integrated supporting organization under IRC §§ 501(c)(3) and 509(a)(3). The examination found no qualifying distributions to or for it…
IRS reclassifies a bank-trusteed charitable trust from supporting organization to private foundation
This letter changes an organization's foundation status, not its tax-exempt status. The organization is a charitable trust whose sole trustee is a bank, and it had been treating itself as a Type III s…
Organization reclassified as a private non-operating foundation
An organization exempt under IRC § 501(c)(3) claimed that it was a Type III functionally integrated supporting organization under IRC § 509(a)(3). The IRS found that an independent bank trustee contro…
IRS revoked an inactive charity's tax exemption
The IRS revoked an organization's Section 501(c)(3) exemption because it could not show that it still conducted charitable activities. The organization had originally supported the implementation of a…
Organization remained exempt but was classified as a private foundation
The IRS made a final determination that an environmental organization remained exempt under Section 501(c)(3) but did not qualify as a publicly supported charity under Section 509(a)(2). It was theref…
Hair-care nonprofit was denied exemption for benefiting a related salon
The IRS denied Section 501(c)(3) exemption to an organization formed to provide hair-care education, free basic hair services, private classes, consultations, and one cosmetology scholarship. The orga…
Conservation organization remained exempt but became a private foundation
The IRS made a final determination that a land-conservation organization remained exempt under Section 501(c)(3) but did not qualify as a publicly supported charity under Section 509(a)(2). It was the…
Neighborhood association did not qualify as a cemetery company
The IRS denied Section 501(c)(13) exemption to a property owners' association because it did not operate a cemetery or perform related burial functions. The association held annual meetings about repa…
Charity lost exemption after routing donations to related for-profit entities
The IRS revoked a charity's Section 501(c)(3) status after finding that its primary activity was collecting donations and making grants to related for-profit entities. The organization did not select …
IRS revokes charity status for private benefit and inurement
A charity collected donations and transferred funds to related for-profit companies, including companies connected to a former officer. The IRS found that the charity did not control how the recipient…
Member burial-benefit group was denied charitable exemption
A membership organization sought Section 501(c)(3) exemption for a program that paid a fixed burial benefit to a member's family when the family lost a loved one. Member dues and new-member registrati…
Exemption revoked after charity ceased operations and became for-profit
A Section 501(c)(3) organization had provided day-care services but later stopped those services, ceased exempt operations, and was administratively dissolved by its state. The examination report says…
Cannabis-festival organization's exemption was revoked
A Section 501(c)(3) organization created and operated a street festival featuring entertainment, food, a beer garden, and vendors connected to the cannabis industry. Its articles listed charitable, ed…
NIL collective was denied charitable exemption
An organization collected donations and entered name, image, and likeness agreements with university student-athletes. The athletes performed community-service hours with local charities and promoted …
Homebuyer counseling and realtor referral group was denied exemption
An organization offered free budgeting, credit-review, financial-literacy, and mortgage-readiness services to prospective home buyers. After a client chose to lease or buy, the client could work with …
Industry standards certification income was not unrelated business income
A Section 501(c)(6) industry association developed safety and environmental management standards and also certified facilities to comparable standards created by an unrelated international standards b…
Trust lost exemption after failing to provide examination records
A trust recognized as a Section 501(c)(3) non-functionally integrated supporting organization was selected for examination. The IRS repeatedly requested records through an appointment letter, extensio…
Private-road homeowners association was denied exemption
A mutual-benefit road association owned and maintained a private roadway serving the residential lots of its members. The road was the members' sole ingress and egress to a public road, was marked as …
Homeowners association was denied charitable exemption
A homeowners association applied for Section 501(c)(3) status on Form 1023-EZ while identifying itself as an unincorporated association. State records instead showed that it was a corporation whose ar…
NIL collective was denied charitable exemption
A nonprofit proposed to pay student athletes from one university for personal appearances and social media posts promoting nearby charities. It argued that the arrangement would expand the charities' …
Trust was reclassified as a private foundation
A charitable trust had been classified as a Type III functionally integrated supporting organization under Section 509(a)(3). After regulatory changes, it reported that it did not provide required ann…
Local business association was denied charitable exemption
A member-supported association sought Section 501(c)(3) status while promoting small businesses in a rural community. Its activities included vendor events, parades, business awards and publicity, net…
Sports festival was denied charitable exemption
An organization sought Section 501(c)(3) status for an annual festival featuring trail and mountain-bike races, children's events, clinics, and other activities. It said the festival promoted physical…
Private social club was denied charitable exemption
An organization sought recognition as a tax-exempt charity under Section 501(c)(3). Its articles described it as a private social club, and its activities included weddings, showers, reunions, festiva…
Supporting organization was reclassified as a private foundation
A tax-exempt charitable trust had been classified as a supporting organization under Section 509(a)(3). The IRS found that the supported charity did not appoint or share the trust's governing body, ha…
Charity lost exemption after failing to provide records
A charitable organization under examination did not provide the organizational and financial records requested by the IRS, including records of its receipts, expenditures, and activities. Its represen…
Fraternal insurer was denied charitable exemption
A local chapter of a fraternal benefit society applied for recognition as a charity under Section 501(c)(3). It was organized as a mutual-benefit corporation to provide fraternal life insurance, meet …
Fund for two named people was denied charitable exemption
A nonprofit corporation was formed to raise money for the living and medical expenses of two named individuals and their families. It held clay-shooting, raffle, and other sporting fundraisers and als…
Exemption was revoked for missing records and no shown exempt activity
An educational charity was examined after filing returns that, according to the IRS, showed little or no spending on exempt program services. A former officer also reported a dispute involving alleged…
Related for-profit use caused community center's exemption denial
A nonprofit planned to own and maintain a community center used for church services, free community activities, and paid events. A for-profit company created and directed by two members of the nonprof…
Contract-bound pageant awards did not support charitable exemption
An organization promoted western culture and rodeo through pageants, clinics, schools, and scholarships for winning contestants. Its articles provided that assets on dissolution would go to a similar …
Exemption was revoked after examination requests went unanswered
A Section 501(c)(3) organization had filed a mix of Forms 990-N and Form 990 and had not filed a Form 990-series return for another period. The IRS selected one Form 990-N year for examination and sen…
Charity lost exemption for uncontrolled and undocumented transfers
A charity raised funds for assistance in the United States and foreign countries and made many payments to individuals and organizations. The IRS found that recipients were often identified through fr…
Homeowners association denied Section 501(c)(3) exemption
A homeowners association sought recognition under Section 501(c)(3). Its articles focused on managing and maintaining common areas, preserving and controlling residential lots, and promoting the healt…
Organization loses exemption over real-estate deals and private benefits
The IRS revoked a tax-exempt organization's status under section 501(c)(3) after finding that substantial parts of its operations did not further exempt purposes. The organization directed proceeds fr…
Farmers’ market denied exemption for commercial activity and vendor benefit
An organization applied for section 501(c)(3) status to operate a farmers’ market offering stalls to local farmers, artisans, food vendors, clubs, and other organizations. Vendors paid weekly or annua…
Farmers’ market denied agricultural-organization exemption
An organization sought section 501(c)(5) status for operating a farmers’ market that charged farmers and vendors to sell directly to consumers. It also ran a winter market for crafts, furniture, and o…
Organization loses exemption after refusing examination requests
The IRS revoked an organization’s section 501(c)(3) status after it failed to cooperate with an examination. The examination file describes repeated letters, delinquency notices, telephone calls, and …
Open-source software group denied charitable exemption
An unincorporated association sought section 501(c)(3) status to finance and coordinate development of an open-source operating system. A related for-profit company owned the copyrights, while the app…
Supporting organization lost exemption after scholarship activity stopped
A tax-exempt supporting organization existed to fund scholarships for students connected with a supported public charity. It had not awarded scholarships or otherwise distributed funds for the support…
Inactive nonprofit lost exemption after incomplete dissolution
A supporting organization told the IRS that it had ended operations, filed a final Form 990-EZ, and distributed its remaining assets to another section 501(c)(3) organization. It relied on a state adm…
Shopping-center association denied business-league exemption
A commercial condominium association sought exemption as a business league under section 501(c)(6). Its member merchants paid fees and assessments that funded maintenance, repairs, landscaping, refuse…
Hereditary-society umbrella group denied charitable exemption
An association sought section 501(c)(3) status for helping founders create hereditary and lineage societies. It advised new groups about bylaws, officer duties, fees, insignia, applications, bank acco…
Rural business group denied charitable exemption
An unincorporated, member-driven organization sought section 501(c)(3) status while supporting businesses in a small rural community. Its activities included vendor fundraisers, holiday events, parade…
Counseling subsidy group denied reinstatement
An organization whose exemption had been automatically revoked sought reinstatement under section 501(c)(3). It raised donations to subsidize counseling and coaching supplied by a particular life coac…
Cook-off fundraising group denied charitable exemption
A group sought section 501(c)(3) status for raising money through cooking competitions and related fundraising. Donations and sponsorships paid entry fees, food, beverages, cooking supplies, and event…
Charity reclassified after it stopped operating a hospital
A section 501(c)(3) organization had been classified as a hospital under section 170(b)(1)(A)(iii). After it sold the hospital, its remaining operations were a home health service and a skilled nursin…
Foreign-support charity reclassified as publicly supported
A section 501(c)(3) organization had been classified as a Type III functionally integrated supporting organization while supporting an organization formed outside the United States. Treasury regulatio…
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.