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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IRS revokes an arts-philanthropy charity whose main activity was investing in private secured loans
The IRS revoked the 501(c)(3) exemption of a nonprofit that had been incorporated to "promote philanthropy within the community through the Arts" and was recognized as a public charity after filing…
IRS revokes an inactive educational private foundation and asserts a 4942 excise tax in the alternative
The IRS revoked the 501(c)(3) exemption of a nonprofit that had been organized to bring technology into schools (providing infrastructure, software, hardware, and support services to enhance…
IRS revokes a scholarship charity whose incorporation papers lacked a purpose limitation and dissolution clause
The IRS revoked the 501(c)(3) exemption of a charity that awards scholarships to students at a specific school, not because of what it did, but because of what its organizing paperwork left out. To…
IRS revokes a 501(c)(4) civic group that mainly ran a bar and gaming room for a related veterans post
The IRS revoked the 501(c)(4) social-welfare exemption of a civic organization whose main activity was running a bar and a gaming room (pull-tabs and lottery-type games) for the members of a related…
IRS revokes a members' club's 501(c)(3) status because its activities were primarily social and recreational
The IRS revoked the 501(c)(3) exemption of a members' club that had been organized around promoting a standard and educating people about care requirements (its articles simply say it operates "as a…
IRS revokes a 501(c)(3) that never responded to the audit or produced records
The IRS revoked the 501(c)(3) exemption of an organization that simply did not cooperate with its audit. The audit report walks through months of certified letters and phone calls to the group's…
IRS revokes a members-only horse boarding club for serving private, not public, interests
The IRS revoked the 501(c)(3) exemption of an organization that runs a horse boarding facility for its own club members. The group collects dues and fees from members to cover operating costs…
IRS revokes a charity that ran a for-profit coffee shop instead of its promised training program
The IRS revoked the 501(c)(3) exemption of an organization that had been recognized on the promise that it would run in-house training programs and employment for survivors of a particular hardship…
501(c)(3) status revoked for failing to respond to an audit and for defective organizing documents
The IRS revoked a group's recognition as a tax-exempt charity under section 501(c)(3). The organization was selected for audit, but it never provided the records the IRS repeatedly asked for. The…
501(c)(7) social club loses exemption for too much investment income (over the 35% limit)
A tax-exempt social club under section 501(c)(7) (the kind of exemption used by alumni associations and similar member clubs) lost its exemption because too much of its money came from outside its…
Self-declared 501(c)(4) disqualified as a never-active shell with no social-welfare activity
The IRS issued a final determination that an organization did not qualify as a 501(c)(4) social welfare organization. The group had never applied for or received a determination letter; it simply…
Fraternity alumni group denied 501(c)(7) social club status
An alumni organization tied to a college fraternity applied to be reinstated as a 501(c)(7) social club after its earlier group-ruling exemption was automatically revoked for failing to file…
Masonic fraternal order denied 501(c)(3) charity status (it fits 501(c)(10))
A Masonic-style fraternal order applied to be recognized as a 501(c)(3) charity using the streamlined Form 1023-EZ, and the IRS denied it. When the IRS asked for the group's actual Articles of…
501(c)(3) status revoked for failing to produce records during an audit
The IRS revoked a charity's 501(c)(3) exemption because it would not turn over the financial records the IRS needed to audit it. The examiner spent months trying: the first appointment letter came…
501(c)(7) social club loses exemption because its main activity was managing property, not member recreation
A tax-exempt social club under section 501(c)(7) lost its exemption after an IRS audit found it was really in the business of managing real estate rather than providing recreation and fellowship to…
501(c)(3) veterans charity revoked for private-benefit real-estate deals, undocumented grants, and a missing dissolution clause
A veterans-assistance charity recognized as a 501(c)(3) public charity lost its exemption after an IRS audit found three problems. First, its articles of incorporation lacked the dissolution clause…
501(c)(6) denied to a farmers'-market group that serves its own vendors, not a whole line of business
An organization that runs a weekly summer farmers' market (plus a one-day festival) applied to be recognized as a tax-exempt business league under section 501(c)(6), and the IRS denied it. To…
501(c)(3) revoked because its charter gives assets to members on dissolution (fails the organizational test)
A regional association that coordinates member-club shows and awards an annual scholarship, recognized as a 501(c)(3) public charity (classified under 509(a)(2)), lost its exemption on a technical…
IRS revokes a fraternity chapter-house club's 501(c)(7) exemption for leasing its house to nonmembers and losing member fellowship
A tax-exempt social club, described in the record as a fraternity or sorority chapter-house corporation, lost its federal income tax exemption. To qualify under IRC Section 501(c)(7), a club must…
IRS denies 501(c)(7) exemption to a club funded by hall rentals, catering, and a bar that also pays member death benefits
An organization applied to be recognized as a tax-exempt social club under IRC Section 501(c)(7), and the IRS turned it down. A qualifying social club must be run mainly for the pleasure and…
IRS denies 501(c)(3) status to a fee-based health care sharing membership program as serving private, commercial interests
An organization that runs a health care sharing program applied for charitable tax-exempt status under IRC Section 501(c)(3), and the IRS denied it. Members pay a monthly fee and, in return, get…
IRS denies 501(c)(3) status to a homeowners association operated for the private benefit of its residents
A homeowners association applied for charitable tax-exempt status under IRC Section 501(c)(3) using the streamlined Form 1023-EZ, and the IRS denied it. The association maintains common areas,…
IRS revokes a dormant Type I supporting organization's 501(c)(3) exemption for years of no exempt activity
A charity that had been recognized as a Type I supporting organization under IRC Section 501(c)(3) lost its exemption because it stopped doing anything. To keep 501(c)(3) status, an organization…
IRS revokes a charity's 501(c)(3) exemption after it would not let the agency examine its records
This is a final adverse determination letter revoking an organization's tax-exempt status under Section 501(c)(3). The organization ran an annual performing and visual arts festival and had been…
IRS revokes a 501(c)(3)'s exemption after it would not produce records to prove it met the organizational and operational tests
This is a final adverse determination revoking an organization's tax-exempt status under Section 501(c)(3). The group had obtained recognition by filing a streamlined Form 1023-EZ and was later…
IRS revokes a swim club's 501(c)(7) exemption for excess nonmember income from renting its parking lot
This is a final adverse determination revoking a social club's tax-exempt status under Section 501(c)(7). The club was formed to run a swimming pool for its members, but the pool closed for lack of…
IRS revokes a 501(c)(3)'s exemption, finding it ran a commercial behavioral-health business, was not a church, and let earnings inure to its officers
This is a final adverse determination revoking an organization's 501(c)(3) exemption after a church tax inquiry and examination under Section 7611. The group was recognized as a charity but later…
IRS denies 501(c)(4) status to an economic-development corporation that buys, develops, and sells land like a for-profit
An organization applied for tax-exempt status as a social welfare group under Section 501(c)(4). It was an economic-development corporation for a small rural town, formed to attract businesses and…
IRS denies 501(c)(10) fraternal exemption to a property-holding entity
An organization applied to be recognized as a tax-exempt domestic fraternal society under Section 501(c)(10). Its only activity was owning a building it rented to a related fraternal lodge; its…
IRS denies 501(c)(3) status to a foreign political party organization
An organization applied to be recognized as a tax-exempt charity under Section 501(c)(3). Its own articles of incorporation described it as a political party, and its stated aims were to build and…
IRS denies 501(c)(3) status to a recreational soccer club
A recreational soccer club applied for tax-exempt charitable status under Section 501(c)(3) using the streamlined Form 1023-EZ. After the IRS asked for more detail, the facts showed the club exists…
IRS denies 501(c)(3) status to a business networking group
A group of business owners and skilled tradespeople applied for tax-exempt charitable status under Section 501(c)(3) using the streamlined Form 1023-EZ. Its activities were running a farmers market…
Virtual-reality entertainment platform did not qualify under section 501(c)(3)
A nonprofit corporation proposed to build and maintain an open virtual-reality platform where users could socialize, play games, enter tournaments, and connect with proprietary platforms. Its…
Charity revoked for undocumented activity and personal expenses
The IRS revoked an organization's section 501(c)(3) status because it did not document activities that furthered an exempt purpose and did not substantiate that its president's expenditures served…
Member fishing club denied section 501(c)(3) status
An organization applied for section 501(c)(3) status for activities centered on fishing meetings, member tournaments, and discussions of fishing and outdoor topics. It also held some events…
202313010: Large stock bequest qualifies as an unusual grant for public-support testing
A publicly supported charity expected a large bequest of company stock that, if counted normally, would cause it to fail the public-support test. The donor had no control over the charity and had…
202313009: IRS denies exemption to social fraternity involved in political campaigning
A fraternity-like organization sought section 501(c)(3) status and described its members as sharing democratic, freedom, and equal-justice principles tied to a related organization in another…
202311007: IRS denies exemption to group promoting a local business district
An organization sought section 501(c)(3) status for activities promoting a local industrial market where the public could visit craft beverage producers and other businesses. It held wine tastings,…
202311006: IRS denies exemption to commercial credit-repair organization
An organization applied for recognition as a section 501(c)(3) charity and described its work as credit education, budgeting help, and document preparation. Its website offered several paid service…
501(c)(3) exemption denied to an employees' collective-bargaining association
An organization made up of employees of a local school district applied for 501(c)(3) charitable/educational status using the streamlined Form 1023-EZ. When the IRS asked for more detail, its…
501(c)(7) social-club exemption denied to a student-athlete funding group
A membership organization applied for tax exemption as a 501(c)(7) social club using Form 1024. Its sole purpose was to raise money from members and donate it to local student athletes, giving funds…
501(c)(3) exemption denied to a city-promotion events group
A nonprofit applied for 501(c)(3) charitable status using the streamlined Form 1023-EZ. Its mission was to hold events promoting a city, with the goal of attracting new businesses and residents and…
One-time cash grant from a dissolving hospital is an "unusual grant" excluded from the public-support test
Public charities have to keep getting enough of their money from the general public to stay "publicly supported"; a single huge gift can throw off that math and jeopardize their status. The tax…
Dog-training and breed-evaluation club denied 501(c)(3) exemption
A club applied for 501(c)(3) charitable/educational status using the streamlined Form 1023-EZ, describing its mission as training owners and handlers of a certain breed of dogs and promoting the…
Racing-sport organization denied 501(c)(6) business-league exemption
An organization applied to be recognized as a tax-exempt business league under section 501(c)(6), the category that covers chambers of commerce and boards of trade. Its actual purpose was to promote…
202308012: IRS denies 501(c)(3) status to a "time bank" barter cooperative that mainly served the private interests of its own members
The IRS denied tax-exempt status under 501(c)(3) to a nonprofit that ran a "time bank." In a time bank, members earn one time-dollar for each hour of service they give and can spend those…
202308011: IRS revokes a 501(c)(3) that ignored an audit, after repeated mailed notices and roughly twenty unanswered phone calls to its officers
The IRS revoked a charity's 501(c)(3) status because it never responded to an audit. The organization had been recognized as exempt after filing the streamlined Form 1023-EZ. When the IRS selected…
Faith-based matchmaking and social-event club denied 501(c)(3) status as a commercial venture serving private interests
An organization applied to be recognized as a tax-exempt charity under Section 501(c)(3). It planned to run an exclusive faith-based social club, a paid matchmaking service where clients hire it to…
501(c)(7) social club status revoked from a fraternity chapter that lost its members and lived on investment income
The IRS revoked the tax-exempt status of a social club under IRC Section 501(c)(7). The club was a local fraternity chapter that had been granted exemption as a social club and, for years, owned a…
Self-declared social-welfare group that was never active disqualified under 501(c)(4)
The IRS issued a final determination that an organization does not qualify as a social welfare organization under IRC Section 501(c)(4) for the years examined. The organization had never applied for…
501(c)(3) status revoked from a charity that raised almost no funds and kept no records
The IRS revoked a charity's tax-exempt status under IRC Section 501(c)(3). The organization said its mission was to raise funds for other charities by buying assets, having them appraised, giving…
Home-care agency serving one disabled person denied 501(c)(4) social-welfare exemption
A nonprofit corporation applied to be recognized as a tax-exempt social welfare organization under IRC Section 501(c)(4). It was a state-approved "home provider agency" formed exclusively to care…
Self-declared "social welfare" group that was never active is disqualified from 501(c)(4) status
A group had filed Forms 990 claiming to be a 501(c)(4) civic league or social welfare organization, but it never got a formal determination from the IRS and never filed the required notice of intent…
Foster-care charity loses 501(c)(3) status for funneling a percentage of its revenue to a for-profit management company owned by its founder and his wife
A tax-exempt charity that placed children in foster homes signed a management agreement handing day-to-day control of its operations to a for-profit management company. The catch: that company was…
One-time cash grant from a dissolving hospital counts as an "unusual grant," so it will not blow the recipient charity's public-support status
A public charity has to keep drawing a broad base of public support to stay classified as publicly supported rather than a private foundation. A single very large gift can distort that math and push…
501(c)(3) application denied to a membership hunting club that serves its members' recreational interests
An organization applied for 501(c)(3) charitable status using the short Form 1023-EZ, describing itself as a "Hunting Organization." On closer review, the IRS found it was a membership hunting club:…
501(c)(3) supporting organization loses exemption after it ceased operations and went inactive
The IRS revoked the tax exemption of a public charity that had been recognized under section 501(c)(3) and classified as a supporting organization under section 509(a)(3). The organization had been…
501(c)(3) application denied to a for-profit corporation that funds and advises businesses for "repayment fees"
An organization applied for recognition as a 501(c)(3) charity, describing its mission as creating opportunities for the underprivileged and helping entrepreneurs grow their businesses. The IRS…
501(c)(3) private foundation loses exemption after it went inactive; founder agreed to revocation
The IRS revoked the tax exemption of a small organization that had been recognized as a 501(c)(3) private foundation. To keep exemption, a 501(c)(3) must be both organized and operated exclusively…
501(c)(7) social club loses exemption because investment income repeatedly exceeded the 35% limit
The IRS revoked the tax exemption of a social club that had been recognized under section 501(c)(7). Social clubs (think recreation associations supported by member dues) get their exemption on the…
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.