Ezel / IRS Rulings / 1021027
Chief Counsel Advice 1021027 Released May 28, 2010 Advice

Counsel says a political subdivision can be a qualified organization under section 170(c)(1)

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This page covers one taxpayer's ruling from 2010, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2010
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

This Chief Counsel Advice addresses whether an organization that is a political subdivision of a state can be a qualified organization for purposes of IRC § 170(c)(1). The advice states that such an organization can be a qualified organization under that provision.

Ruling snapshot

  • Question: Can a political subdivision of a state qualify as a qualified organization under IRC § 170(c)(1)?
  • Outcome: Advice given
  • Key authorities: IRC § 170(c)(1)

Full text (IRS public release)

ID: CCA-113831-10 Number: 201021027
Release Date: 5/28/2010
Office: -----------------------------
UILC: 170.14-02

From: --------------------------
Sent: January 13, 2010 8:31 AM
To: ----------------------
Cc: --------------------
Subject: qualified organization questions

If the organization is a political subdivision of the state for the purpose of section 170(c)(1), it can be a
qualified organization.

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