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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Foundation reclassified as a Type III functionally integrated supporting organization
A tax-exempt trust supported a named historical society by funding property maintenance, renovations, historical artifacts, equipment, and the operation of a museum and farm. Its earlier…
Exemption revoked for organizational and recordkeeping failures
The IRS revoked an organization's section 501(c)(3) exemption effective January 1, 2018. The organization's articles of incorporation did not satisfy the organizational test for tax-exempt status.…
Horse competition organization denied charitable status
An organization applied for section 501(c)(3) status to promote the breeding, development, training, and competition of purpose-bred event horses. It planned to collect entry fees, publicize…
Charity revoked for insider benefits and inadequate grant records
The IRS revoked an organization's section 501(c)(3) status after examining its grants and governance. The organization had no active board oversight, and one officer controlled operations and…
Charity status revoked after failure to provide audit records
The IRS revoked an organization's section 501(c)(3) status after it failed to respond to repeated audit letters and telephone calls. The organization did not provide records of its receipts,…
Commercial certification and consulting model denied exemption
An organization sought section 501(c)(3) status for a program promoting a redacted philosophy and movement. It planned to certify businesses, provide consulting, license a label, promote subscribers…
Failure to provide records and state dissolution led to revocation
The IRS revoked a charity's section 501(c)(3) status after it failed to respond to repeated requests for books, financial records, board minutes, and information about its activities. Without those…
Charity lost exemption after ignoring audit record requests
The IRS revoked an organization's section 501(c)(3) status after it failed to provide records requested during an examination. The organization had received exemption through Form 1023-EZ and later…
IRS revokes a 501(c)(3)'s exemption on three grounds, including a court-ordered dissolution for fraud
This final IRS letter revokes a charity's 501(c)(3) exemption on three separate grounds. First, the operational test: after the IRS opened an audit and asked for standard financial records, the…
IRS revokes a 501(c)(3)'s exemption for ignoring an audit
This final IRS letter revokes a small charity's 501(c)(3) exemption because it would not cooperate with an audit. The organization had used the streamlined Form 1023-EZ to attest that it was…
IRS denies 501(c)(3) status to a member-artist cooperative gallery that serves its artists' private interests
This is a final IRS letter denying an organization's application for 501(c)(3) tax-exempt status. The applicant runs an art gallery that exhibits and sells the work of its own member artists.…
IRS denies 501(c)(3) status to a business association that serves its members' private interests
This is a final IRS letter denying an organization's application for 501(c)(3) tax-exempt status. The applicant is a business association that represents companies of a particular nationality across…
IRS denies 501(c)(5) status to a group that just manages a subdivision's cattle-grazing lease
This is a final IRS letter denying an organization's application for tax-exempt status as an agricultural organization under Section 501(c)(5). The applicant's only activity is managing a…
IRS denies 501(c)(3) exemption to a healing "church" whose ceremonies distribute a Schedule I hallucinogen
This is a final IRS letter denying an organization's application for 501(c)(3) tax-exempt status. The applicant described itself as a church built around an ancient religious practice: it holds…
IRS revokes a 501(c)(3)'s exemption back to January 2021 for ignoring an audit
This final IRS letter revokes a small charity's 501(c)(3) exemption, effective January 1, 2021, because it would not cooperate with an audit. The organization was incorporated as a nonprofit with a…
IRS revokes a 501(c)(3)'s exemption for ignoring an audit of its records
This final IRS letter revokes a small charity's 501(c)(3) exemption on a single ground: it would not cooperate with an audit. The organization was incorporated as a nonprofit, recognized as a public…
IRS revokes a 501(c)(3)'s exemption for ignoring an audit of its records
This final IRS letter revokes a small charity's 501(c)(3) exemption because it would not cooperate with an audit. The organization was incorporated as a nonprofit, recognized as a public charity,…
IRS revokes a cancer-aid charity's exemption for a defective charter and for ignoring an audit
This final IRS letter revokes a small charity's 501(c)(3) exemption on two independent grounds. First, the organizational test: to be exempt, a nonprofit's articles of incorporation must limit its…
IRS revokes a 501(c)(3)'s exemption for ignoring an audit and being court-dissolved for charity-fraud, made retroactive to the dissolution date
This final IRS letter revokes a small charity's 501(c)(3) exemption on multiple grounds. The organization was incorporated as a nonprofit, recognized as a public charity, and filed Form 990-N (the…
IRS revokes a 501(c)(3) charity's exemption after it ignored an audit of its records
This is a final IRS letter revoking a small charity's tax-exempt status under Section 501(c)(3). The organization was incorporated under a state Not-for-Profit Corporation Law, won recognition as a…
IRS revokes a charity's 501(c)(3) status on multiple grounds, a charter purpose broader than 501(c)(3) with no dissolution clause, failure to answer an audit, and court-ordered dissolution after a state attorney general's fraud suit
This is a final IRS determination revoking the federal tax-exempt status of an organization recognized as a 501(c)(3) public charity through the streamlined Form 1023-EZ application. The final…
IRS revokes a charity's 501(c)(3) status on two grounds, ignoring an audit and court-ordered dissolution after a state attorney general won summary judgment for charities-law and consumer-fraud violations, made retroactive to the dissolution date
This is a final IRS determination revoking the federal tax-exempt status of an organization recognized as a 501(c)(3) public charity on a Form 1023 application. The revocation rests on two…
IRS revokes a charity's 501(c)(3) status for not answering an audit and, in its final letter, adds that the state involuntarily dissolved the group for charitable-solicitation and consumer-protection violations
This is a final IRS determination revoking the federal tax-exempt status of an organization first recognized as a 501(c)(3) public charity on a full Form 1023 application. Its exemption was…
IRS revokes a charity's 501(c)(3) status for not answering an audit; the group had been auto-revoked for nonfiling, later reinstated, then renamed, and used a commercial UPS-store mailbox while still active with the state
This is a final IRS determination revoking the federal tax-exempt status of an organization that had a complicated history with the IRS. It was first recognized as a 501(c)(3) public charity on a…
IRS revokes a charity's 501(c)(3) status for not answering an audit; the organization and its managing director shared a commercial UPS-store mailbox, though the entity was still active with the state
This is a final IRS determination revoking the federal tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity through the streamlined Form 1023-EZ application.…
IRS revokes a charity's 501(c)(3) status on two grounds, failure to answer an audit and court-ordered dissolution after a state attorney general's fraud suit
This is a final IRS determination revoking the federal tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity through the streamlined Form 1023-EZ application.…
IRS revokes a charity's 501(c)(3) status for not answering an audit; its officers used two commercial UPS-store mailboxes and the state had forfeited the corporation for unpaid franchise tax
This is a final IRS determination revoking the federal tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity through the streamlined Form 1023-EZ application.…
IRS revokes a charity's 501(c)(3) status for ignoring an audit; the organization, its managing director, and its executive director all used commercial mailbox addresses, though the entity was still active with the state
This is a final IRS determination revoking the federal tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity. The organization filed only electronic-notice…
IRS revokes a charity's 501(c)(3) status on two grounds, a charter purpose too broad for 501(c)(3) and a failure to answer an audit, while its officers used commercial mailbox addresses
This is a final IRS determination revoking the federal tax-exempt status of a nonprofit corporation that had been recognized as a 501(c)(3) public charity. The IRS gives two independent reasons.…
IRS revokes a charity's 501(c)(3) status for ignoring an audit; the group and its officers used commercial mailbox addresses and the state had suspended it
This is a final IRS determination revoking the federal tax-exempt status of a nonprofit corporation that had been recognized as a 501(c)(3) public charity. Its stated purpose was to provide food,…
IRS revokes a charity's 501(c)(3) status for ignoring an audit; its managing director and the organization shared a commercial mailbox, though the entity was still active with the state
This is a final IRS determination revoking the federal tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity. The organization filed only electronic-notice…
IRS revokes a charity's 501(c)(3) status for ignoring an audit; its officers used a now-closed commercial mailbox and the state had marked it delinquent and mailed a dissolution notice that came back undeliverable
This is a final IRS determination revoking the federal tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity. The IRS selected it for a mail audit and requested…
IRS revokes a charity's 501(c)(3) status for ignoring an audit; its officers and the organization used a UPS-store mailbox, though the corporation was active and filing state annual reports
This is a final IRS determination revoking the federal tax-exempt status of a nonprofit corporation that had been recognized as a 501(c)(3) public charity. The organization had used the streamlined…
IRS revokes a charity's 501(c)(3) status for ignoring an audit; its officers and the organization shared a UPS-store mailbox, though the entity was still active with the state
This is a final IRS determination revoking the federal tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity. The organization had used the streamlined Form…
IRS revokes a charity's 501(c)(3) status for ignoring an audit; its officers shared a now-closed UPS-store mailbox and the state had marked it delinquent for unfiled annual reports
This is a final IRS determination revoking the federal tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity. The organization had used the streamlined Form…
IRS revokes a public-benefit corporation's 501(c)(3) status for ignoring an audit; it used commercial mailbox addresses and the state had suspended it
This is a final IRS determination revoking the federal tax-exempt status of a nonprofit public benefit corporation that had been recognized as a 501(c)(3) public charity. The organization had used…
IRS revokes a charity's 501(c)(3) status on two grounds, ignoring an audit and losing its corporate existence, after a state attorney general found the group was procured through fraud
This is a final IRS determination revoking the federal tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity. Its stated purpose was to provide food, clothing,…
IRS revokes a charity's 501(c)(3) status after it ignored an audit; its officers used commercial UPS-store mailbox addresses and the state had forfeited the entity for unpaid franchise tax
This is a final IRS determination revoking the federal tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity. The organization had used the streamlined Form…
IRS revokes a charity's 501(c)(3) status for failing to respond to an audit; its officers shared a now-closed commercial mailbox and the state had marked it delinquent
This is a final IRS determination revoking the federal tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity. The IRS selected the organization for a mail audit…
IRS revokes a charity's 501(c)(3) status for failing to answer an audit and after the state involuntarily dissolved it in an attorney-general fraud case
This is a final IRS determination revoking the federal tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity. Its stated charitable purpose was providing food,…
202338026: IRS revokes a 501(c)(3) for ignoring an audit; it used a UPS store mailbox that had closed, the state administratively dissolved it, and it was not a listed chapter of the charity network its name suggested
The IRS revoked a charity's 501(c)(3) tax-exempt status because it never responded to an audit. The organization had been recognized as exempt through a streamlined application in which it attested…
202338025: IRS revokes a 501(c)(3) that ignored an audit and was dissolved by court order after the state attorney general sued it and related nonprofits for fraud
The IRS revoked a charity's 501(c)(3) tax-exempt status on two grounds. First, it never responded to an audit: after the IRS asked for basic records (chart of accounts, general ledger, bank…
202338024: IRS revokes a 501(c)(3) for ignoring an audit; it operated from a UPS store mailbox, filed only electronic notices, and was not a listed chapter of the charity network its name suggested
The IRS revoked a charity's 501(c)(3) tax-exempt status because it never responded to an audit. The organization had been recognized as exempt after filing a full application with a copy of its…
202338023: IRS revokes a 501(c)(3) for ignoring an audit; it filed only empty electronic notices from a UPS store mailbox and was not actually a chapter of the charity network its name suggested
The IRS revoked a charity's 501(c)(3) tax-exempt status because it never responded to an audit. The organization had been recognized as exempt after filing a full application with a copy of its…
202338022: IRS revokes a 501(c)(3) for ignoring an audit; the organization and its officers all used one UPS store mailbox that had closed, and the state placed it in delinquent status
The IRS revoked a charity's 501(c)(3) tax-exempt status because it never responded to an audit. The organization had been recognized as exempt through a streamlined application in which it attested…
202338021: IRS revokes a 501(c)(3) for ignoring an audit; its addresses traced to a retail mailbox store and a shared UPS store mailbox, and its state registration was suspended
The IRS revoked a charity's 501(c)(3) tax-exempt status because it never responded to an audit. The organization had been recognized as exempt through a streamlined application in which it attested…
202338020: IRS revokes a 501(c)(3) for ignoring an audit; its addresses traced to a retail mailbox store and a UPS store and its state registration was suspended
The IRS revoked a charity's 501(c)(3) tax-exempt status because it never responded to an audit. The organization had been recognized as exempt through a streamlined application in which it attested…
202338019: IRS revokes a 501(c)(3) for ignoring an audit; its addresses traced to a retail mailbox store and UPS store mailboxes and its state registration was suspended
The IRS revoked a charity's 501(c)(3) tax-exempt status because it never responded to an audit. The organization had been recognized as exempt through a streamlined application in which it attested…
202338018: IRS revokes a 501(c)(3) for ignoring an audit; its registered office and its application address were both UPS store mailboxes and the state forfeited its registration
The IRS revoked a charity's 501(c)(3) tax-exempt status because it never responded to an audit. The organization had been recognized as exempt through a streamlined application in which it attested…
202338017: IRS revokes a 501(c)(3) for ignoring an audit; its addresses traced to a retail mailbox store and a UPS store, and its state registration was suspended
The IRS revoked a charity's 501(c)(3) tax-exempt status because it never responded to an audit. The organization had been recognized as exempt through a streamlined application in which it attested…
202338016: IRS revokes a 501(c)(3) for ignoring an audit; its application address and its state-registered office were both UPS store mailboxes
The IRS revoked a charity's 501(c)(3) status because it never responded to an audit. The organization had been recognized through a streamlined exemption application, but the address it gave for…
202338015: IRS revokes a 501(c)(3) for ignoring an audit; both its application address and its state-registered office traced to UPS store mailboxes
The IRS revoked a charity's 501(c)(3) status because it never responded to an audit. The organization had been recognized through a streamlined exemption application, but the address it gave for…
202338014: IRS revokes a 501(c)(3) for ignoring an audit; its UPS store mailbox had closed and two state dissolution notices came back undeliverable
The IRS revoked a charity's 501(c)(3) status because it never responded to an audit. The organization had been recognized based on its streamlined Form 1023-EZ. Its addresses, including the one for…
202338013: IRS revokes a 501(c)(3) for ignoring an audit; its office, agent, and directors all used one UPS store mailbox and the website it reported could not be found
The IRS revoked a charity's 501(c)(3) status because it never responded to an audit. The organization had been recognized based on its streamlined Form 1023-EZ. Its incorporator, its resident agent,…
202338012: IRS revokes a 501(c)(3) for ignoring an audit; its addresses were two mailbox-service storefronts and the state had suspended the corporation
The IRS revoked a charity's 501(c)(3) status because it never responded to an audit. Unlike some related cases, this organization's charter satisfied the organizational test: its Articles of…
202338011: IRS revokes a 501(c)(3) that ignored an audit and whose charter purpose was too broad; its statutory-agent address was a permanently closed UPS store
The IRS revoked a charity's 501(c)(3) status on two independent grounds. First, the organization flunked the organizational test: its Articles of Incorporation stated a corporate purpose broader…
202338010: IRS revokes a 501(c)(3) for ignoring an audit; the charity and its managing director shared a single UPS store mailbox
The IRS revoked a charity's 501(c)(3) status because it never responded to an audit. The organization had been recognized based on its streamlined Form 1023-EZ, and both the charity's mailing…
202338009: IRS revokes a 501(c)(3) for ignoring an audit; both of its addresses traced to UPS store mailboxes, though its state charter stayed active
The IRS revoked a charity's 501(c)(3) status because it never responded to an audit. The organization had been recognized based on its streamlined Form 1023-EZ, but both the address on its Articles…
202338008: IRS revokes a 501(c)(3) for ignoring an audit; both its addresses were mailbox services and the state had forfeited its charter
The IRS revoked a charity's 501(c)(3) status because it never responded to an audit. The organization had been recognized based on its streamlined Form 1023-EZ, but both the registered-agent address…
202338007: IRS revokes a 501(c)(3) after the organization ignored an audit; its Form 1023-EZ address was a UPS store mailbox
The IRS revoked a charity's 501(c)(3) tax-exempt status because it never responded to an audit. The organization had obtained recognition using the streamlined Form 1023-EZ, listing a mailing…
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.