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.

40,104 determinations and counting · Newest release October 9, 2026
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DET

IRS revokes a social welfare organization's tax exemption

An organization had been recognized as tax-exempt under Section 501(c)(4) and reported activities for emergency service workers, including social events, an awards banquet, a scholarship, and…

201830016·July 27, 2018
Revocation
DET

Charity exemption revoked after repeated examination contacts failed

A charity obtained Section 501(c)(3) status through Form 1023-EZ and was later selected for examination. IRS letters sent to several located addresses came back undeliverable or refused, calls to…

201830015·July 27, 2018
Revocation
DET

Inactive research organization agreed to revocation

An organization conducted research and education on adult psychological development through a website, programs, and memberships. After moving to another state, it could not obtain recognition there…

201830014·July 27, 2018
Revocation
CCA

Jeopardy levy may precede normal collection notices

Chief Counsel advised that the IRS can make a jeopardy levy even when it has not made a jeopardy or termination assessment. The levy may occur at several points before the usual notice-and-waiting…

201830013·July 27, 2018
Advice
CCA

Executrix could not disaffirm returns filed before spouse became a surviving spouse

Chief Counsel considered whether an executrix could disaffirm amended returns filed by a decedent's wife for several redacted tax years. Section 6013(a)(3) allows disaffirmance of a return made by a…

201830012·July 27, 2018
Advice
CCA

Unsupported fee estimates did not permit deduction of acquisition costs

A taxpayer paid an investment banker a success-based fee for a completed acquisition and did not elect the Revenue Procedure 2011-29 safe harbor. The banker later estimated that 92% of its time…

201830011·July 27, 2018
Advice
PLR

Partnership received 120 days to make late Section 754 election

A professional-services limited liability company treated as a partnership missed the deadline to make a Section 754 election for the year in which a buyer acquired a partnership interest. The…

201830010·July 27, 2018
Approved
PLR

Company received 60 days to file late LIFO election

A parent company transferred LIFO inventory to an indirectly owned subsidiary in a Section 351 transaction. The subsidiary consistently used LIFO for tax and financial reporting, but the group's tax…

201830009·July 27, 2018
Approved
PLR

Missed QSST election received inadvertent S corporation termination relief

An S corporation shareholder transferred stock through trusts after the shareholder's death. A successor trust qualified to elect as a qualified subchapter S trust, but its initial income…

201830008·July 27, 2018
Approved
PLR

Missed ESBT election received inadvertent S corporation termination relief

A trust acquired S corporation stock from an estate and remained an eligible shareholder for two years. The trustee then failed to timely elect electing small business trust status, causing the…

201830007·July 27, 2018
Approved
PLR

Water agreement does not make reservoir bonds private activity bonds

A government-owned electric utility planned to use tax-exempt bonds to finance part of a reservoir that would improve the reliable supply of water used at its coal-fired energy station. A separate…

201830006·July 27, 2018
Approved
PLR

Parent may claim a worthless-stock deduction using a look-through gross-receipts method

A corporate parent converted an insolvent subsidiary into a disregarded entity and represented that the subsidiary's stock was worthless. The IRS ruled that the parent could claim a worthless-stock…

201830005·July 27, 2018
Approved
PLR

Late QSST election did not end S corporation status

An S corporation shareholder transferred stock to a grantor trust. When the shareholder died, the trust remained an eligible shareholder for two years, but it continued holding the stock after that…

201830004·July 27, 2018
Approved
PLR

Graduation awards are charitable distributions, not taxable expenditures

A private operating foundation provided scholarships and a required financial education program to high-achieving students with financial need from rural counties. Students learned investment skills…

201830003·July 27, 2018
Approved
PLR

Two-year extension preserves bankruptcy liquidating trust status

A trust created under a Chapter 11 bankruptcy plan was established solely to liquidate estate assets and distribute the proceeds to beneficiaries. Its agreement limited business activity and cash…

201830002·July 27, 2018
Approved
PLR

Estate receives 120 days to make a late QDOT election

A decedent left the residue of his estate to his surviving spouse, who was not a United States citizen. Tax advisers told the spouse that a qualified domestic trust was needed for the estate to…

201830001·July 27, 2018
Approved
PLR

Employer-related scholarship procedures receive advance approval

A private foundation proposed a nonrenewable scholarship program for children and dependents of employees of a company and its subsidiaries. An independent committee would select recipients using…

201829024·July 20, 2018
Approved
DET

Foundation loses exemption for private use of charitable assets

A foundation had been created to promote scientific research in physics and cosmology. After its founder died, his wife became president, and the IRS found no ongoing charitable activity,…

201829023·July 20, 2018
Revocation
DET

Bingo organization loses exemption for private benefit and minimal charity

An organization recognized under Section 501(c)(3) held volunteer-run bingo games every Friday and reported no other activity. It made only three charitable contributions during the examined year…

201829022·July 20, 2018
Revocation
DET

Golf club loses social-club exemption for public business activity

A golf club recognized under Section 501(c)(7) operated seasonally and regularly opened its course, carts, food, and bar services to the public. It advertised public weekday access, online tee…

201829021·July 20, 2018
Revocation
DET

Inactive community organization loses Section 501(c)(3) status

An organization had been recognized under Section 501(c)(3) to provide language instruction, translation, help with government forms and job searches, youth support, and assistance to a Muslim…

201829020·July 20, 2018
Revocation
DET

Unfunded organization loses exemption after incomplete dissolution

A recently recognized charity intended to distribute religious teddy bears to children but was unable to obtain funding. Its president said the organization wanted to close, filed a Form 990-N…

201829019·July 20, 2018
Revocation
DET

IRS revokes exemption after organization ignores audit requests

An organization recognized under Section 501(c)(3) was selected for an audit of its Form 990. The IRS repeatedly sent examination letters and information requests and made numerous telephone calls,…

201829018·July 20, 2018
Revocation
DET

Government hospital loses Section 501(c)(3) status for Section 501(r) failures

A government-owned hospital also held a separate Section 501(c)(3) determination, making it a dual-status hospital subject to Section 501(r). The IRS found that the hospital had not adopted an…

201829017·July 20, 2018
Revocation
DET

Exemption revoked after organization failed to provide records

An organization recognized under Section 501(c)(3) did not maintain an available business office or representatives and repeatedly failed to arrange an examination or provide requested…

201829016·July 20, 2018
Revocation
DET

Tourism promoter loses exemption for commercial activities

A destination-marketing organization promoted tourism and local businesses through advertising, trade shows, referrals, visitor guides, and member benefits. Its income came substantially from…

201829015·July 20, 2018
Revocation
DET

Inactive youth-health charity loses exemption

An organization formed to promote health, exercise, and healthy eating among school-age children reported no funding and did not substantiate that it conducted field days, fitness classes, or…

201829014·July 20, 2018
Revocation
DET

Scholarship trust loses exemption for trustee withdrawals

A private-foundation trust made college scholarships but its sole trustee also regularly withdrew substantial trust funds for personal purposes. The trustee recorded the withdrawals as a note…

201829013·July 20, 2018
Revocation
DET

Limited partnership loses exemption after failing examination requests

An organization obtained Section 501(c)(3) status through Form 1023-EZ, but state records identified it as a limited partnership rather than a corporation, association, or trust. During an…

201829012·July 20, 2018
Revocation
DET

Defunct nonprofit loses exemption after failing to provide records

A nonprofit corporation stopped operating and failed to file its required Form 990-N return. Its president told the IRS that the organization had folded, had no assets to distribute, and would…

201829011·July 20, 2018
Revocation
DET

Social club loses exemption for recurring nonmember income

A Section 501(c)(7) social club earned rental income from two apartments above its clubhouse. Its Forms 990 showed recurring nonmember income above the statutory limits: no more than 35 percent of…

201829010·July 20, 2018
Revocation
DET

Jazz organization loses exemption for restaurant-focused activities

An organization formed to advance jazz education moved its performances to a restaurant controlled by substantially the same management. The IRS found that most of its activities consisted of…

201829009·July 20, 2018
Revocation
DET

Cultural organization loses exemption after withholding audit records

A public charity formed to present theater, promote the arts, and revitalize a historic venue did not provide records needed to evaluate its spending, contracts, loans, and possible private benefit…

201829008·July 20, 2018
Revocation
DET

Cemetery loses mistaken Section 501(c)(3) exemption

A cemetery organization had previously been exempt under Section 501(c)(13), but after automatic revocation it reapplied on Form 1023-EZ and obtained Section 501(c)(3) status instead of using Form…

201829007·July 20, 2018
Revocation
DET

Disability-services charity loses exemption for deficient articles and noncooperation

An organization offered therapy, counseling, and educational services to children with disabilities, but its articles of incorporation lacked the required dissolution clause. During an examination,…

201829006·July 20, 2018
Revocation
PLR

Trust modifications preserve GST tax exemption

A decedent’s trust created generation-skipping trusts with zero inclusion ratios because GST exemption was allocated to them. The trustees proposed a court-approved amendment giving each primary…

201829005·July 20, 2018
Approved
PLR

Check-the-box liquidation supports affiliated worthless-stock deduction

A corporate group planned a series of check-the-box elections that would liquidate several foreign subsidiaries up a holding-company chain. The lower-tier liquidations were represented to qualify…

201829004·July 20, 2018
Approved
PLR

Conservation land excluded from minimum investment return

A private operating foundation maintained undeveloped desert land adjoining its historic developed property. The land served as a security buffer for charitable and educational events, supported…

201829003·July 20, 2018
Approved
PLR

Late success-based-fee safe-harbor election granted

A consolidated corporate group paid a contingent adviser fee for an acquisition and reported the fee using Revenue Procedure 2011-29’s safe harbor, deducting 70 percent and capitalizing 30 percent.…

201829002·July 20, 2018
Approved
PLR

Tax-book asset method approved for interest apportionment

A domestic parent of a consolidated group had long used the fair-market-value method to value assets when apportioning interest expense. Maintaining that method created substantial administrative…

201829001·July 20, 2018
Approved
PLR

Waives excise taxes for pension-plan liquidity shortfalls

A company requested relief from excise taxes after its defined benefit pension plan missed required liquidity shortfall contributions for seven quarters. The company had incorrectly believed that a…

201828012·July 13, 2018
Approved
PLR

Scholarship and educational grant procedures are approved

A private foundation requested advance approval for two programs serving students with financial need and academic promise. Its scholarship program would support private high school, college, and…

201828011·July 13, 2018
Approved
PLR

Different averaging rules would violate utility tax normalization

A regulated electric utility used a 13-month average to calculate rate-base items, including accumulated deferred federal income taxes. An IRS audit settlement reduced a deferred tax asset tied to…

201828010·July 13, 2018
Approved
PLR

Assisted-living joint venture rent qualifies as REIT income

A company intending to qualify as a real estate investment trust owned assisted-living facilities through a partnership. The facilities were leased to operating partnerships owned by the REIT's…

201828009·July 13, 2018
Approved
PLR

Senior facilities and foreign income receive mixed REIT rulings

A company planning to elect REIT status acquired independent-living and assisted-living facilities in the United States and another country. The IRS ruled that the integrated senior facilities with…

201828008·July 13, 2018
Mixed outcome
PLR

Subsidiary employees may join parent S corporation's ESOP

An S corporation maintained an employee stock ownership plan holding its privately traded common stock. Its wholly owned C corporation subsidiary planned to hire employees and adopt the parent's…

201828007·July 13, 2018
Approved
PLR

Affiliate's stock-offering profit is excluded from gross income

A publicly traded parent company sold two classes of preferred stock through an underwriting group that included a disregarded entity owned by a consolidated subsidiary. The parent paid underwriting…

201828006·July 13, 2018
Approved
PLR

Grants 120 days for late disregarded-entity election

A foreign eligible entity intended to be treated as disregarded from its formation date but inadvertently failed to file Form 8832 on time. The entity initially had one owner and later became wholly…

201828005·July 13, 2018
Approved
PLR

Grants late disregarded-entity election before partnership conversion

A foreign eligible entity intended to be treated as disregarded from its formation date but inadvertently failed to file Form 8832 on time. It initially had one owner and later became a…

201828004·July 13, 2018
Approved
PLR

Grants 120 days for foreign entity's late classification election

A foreign eligible entity had been indirectly wholly owned by the same taxpayer since its formation. It intended to elect disregarded-entity status from that date but inadvertently failed to file…

201828003·July 13, 2018
Approved
PLR

Grants 120 days for wholly owned foreign entity's late election

A foreign eligible entity had been wholly owned by one taxpayer since it was formed. It intended to be treated as disregarded from its formation date but inadvertently failed to file Form 8832 on…

201828002·July 13, 2018
Approved
PLR

Grants late election before foreign entity became a partnership

A foreign eligible entity intended to be disregarded from its formation date but inadvertently failed to file Form 8832 on time. It was initially wholly owned by one taxpayer and later became a…

201828001·July 13, 2018
Approved
DET

Law-enforcement association denied VEBA exemption

A membership organization for active and retired law-enforcement officers applied for exemption as a voluntary employees' beneficiary association under Section 501(c)(9). It collected dues and…

201827014·July 6, 2018
Denied
DET

Political association denied charitable exemption

An unincorporated association sought recognition as a Section 501(c)(3) charity. Its bylaws promoted political activity, required officers and members to be voters of one political party, and…

201827013·July 6, 2018
Denied
CCA

Judicial approval protects specified principal residences from levy

Chief Counsel advised that judicial approval is required before the IRS levies property owned by a taxpayer and used as the principal residence of the taxpayer, the taxpayer's spouse, former spouse,…

201827012·July 6, 2018
Advice
CCA

Index swaps disallow ETF dividends-received deductions

A corporate group bought shares of an exchange-traded fund that tracked a stock index while entering into short swaps tied to the same index. The positions offset the ETF's price and dividend risk,…

201827011·July 6, 2018
Advice
PLR

Restores S status after three years of passive income

An S corporation had accumulated earnings and profits from its prior C corporation period and received more than 25 percent passive investment income for three consecutive years. Those facts…

201827010·July 6, 2018
Approved
PLR

Grants 45 days for late success-fee safe-harbor election

A corporation paid a success-based financial advisory fee in connection with a stock acquisition. Its tax preparer did not advise it to elect the Revenue Procedure 2011-29 safe harbor, which…

201827009·July 6, 2018
Approved
PLR

Corporate separation preserves liquidations and active businesses

A publicly traded foreign parent proposed a 36-step transaction to separate two broad business groups through entity-classification elections, internal transfers, liquidations, contributions,…

201827008·July 6, 2018
Approved
PLR

Grants 60 days for late consolidated-return election

A corporation became the parent of a new affiliated group after acquiring a subsidiary. The group intended to file a consolidated federal return but failed to make a valid election under Treasury…

201827007·July 6, 2018
Approved

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.