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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
IRS revokes a charity's 501(c)(3) status after it went silent during an audit
The IRS selected a § 501(c)(3) charity for examination and repeatedly tried to reach it by mail and phone, but the organization never produced its records. The group appeared to have dissolved with…
IRS revokes a social club's tax exemption for excessive non-member income
A tax-exempt social club (IRC § 501(c)(7)) owned a building with two halls it rented to both member and non-member groups. On audit, the IRS found the club's income from non-members exceeded the…
IRS denies 501(c)(6) business-league status to a common-area maintenance association for a development
An association was set up under a development's declaration of easements, covenants, conditions, and restrictions to own and maintain the common areas of one area (Area 4) of the development. Its…
IRS denies 501(c)(6) business-league status to a common-area maintenance association for a development
An association was set up under a development's declaration of easements, covenants, conditions, and restrictions to own and maintain the common areas of one area (Area 3) of the development. Its…
IRS denies 501(c)(6) business-league status to a common-area maintenance association for a development
An association was set up under a development's declaration of easements, covenants, conditions, and restrictions to own and maintain the common areas of one area (Area 2) of the development. Its…
IRS denies 501(c)(6) business-league status to a common-area maintenance association for a development
An association was set up under a development's declaration of easements, covenants, conditions, and restrictions to own and maintain the common areas of one area of the development. Its members are…
IRS denies 501(c)(4) status to an ethnic mutual-aid society that pays members' funeral costs
A mutual-aid society formed by a group of friends of the same ethnic background, all immigrants from one country, applied to be recognized as a 501(c)(4) social welfare organization. Its main…
IRS denies 501(c)(3) status to a high school class fund set up to pay for reunions
A group formed by a high school graduating class's student government committee applied for 501(c)(3) status using the short Form 1023-EZ, claiming an educational purpose. During high school the…
IRS denies 501(c)(12) status to a statewide insurance risk-sharing pool for water companies
An unincorporated association whose members are mutual water companies in one state applied to be recognized as tax-exempt under section 501(c)(12). That section exempts benevolent life insurance…
IRS revokes a cultural membership group's 501(c)(3) status for running only social activities and failing to keep records
A membership-based cultural and social organization had been recognized as a 501(c)(3) charity in 2009. On examination, the IRS found that the group operated almost entirely as a social club for its…
IRS denies 501(c)(3) status to an adult volleyball club that mainly runs a recreational league
A club applied for recognition as a 501(c)(3) charity using the short Form 1023-EZ. Its stated purpose was to promote volleyball in its region by fielding teams, running local and regional leagues,…
Third companion ruling on a family private foundation moving at least 80% of its assets, including a large bequest, to two related foundations tax-free
This is the third of three companion letters (control numbers PLR-116647-21, PLR-116648-21, and PLR-116649-21) issued the same day on a single transaction. A family-run grant-making private…
Companion ruling letting a family private foundation move at least 80% of its assets, including a large bequest, to two related foundations without termination or excise taxes
This ruling is a companion to PLR 202231006, issued the same day on the same transaction (the two letters carry consecutive control numbers, PLR-116648-21 and PLR-116647-21). A family-run…
Family foundation cleared to move most of its assets, including a large bequest, to two related foundations without triggering private-foundation excise taxes
A family controls three private foundations: an existing family foundation, a company foundation, and a newly created foundation. The family foundation expects a large bequest from a donor who died…
IRS revokes a dormant nonprofit's 501(c)(3) status for years of inactivity
The IRS revoked a nonprofit's recognition as a tax-exempt charity under section 501(c)(3). The organization had been incorporated to run educational and cultural programs, but an examination found…
IRS revokes a nonprofit's 501(c)(3) status after it failed to produce records for an audit
The IRS revoked a nonprofit's recognition as a tax-exempt charity under section 501(c)(3) because it did not cooperate with an examination. The organization had been recognized as a charity after…
IRS revokes a social club's 501(c)(7) exemption because it had no members and lived on rentals to the public
The IRS revoked a nonprofit's recognition as a tax-exempt social club under section 501(c)(7). The organization had started life as a 501(c)(2) title-holding company that simply owned a building;…
IRS denies 501(c)(4) status to a homeowners' group that maintains one private road for its own members
The IRS denied recognition as a tax-exempt social welfare organization under section 501(c)(4) to a group of homeowners formed as a mutual benefit corporation. Their sole purpose was to maintain and…
IRS revokes a 501(c)(7) club's exemption where it had no members and lived entirely on investment income
The IRS revoked an organization's recognition as a tax-exempt social club under section 501(c)(7). The group had been an alumni-support fund: it held the cash value of a former chapter house in an…
IRS denies 501(c)(3) status to a disc golf club because its recreational purpose is substantial
The IRS denied recognition as a tax-exempt charity under section 501(c)(3) to an organization that promotes disc golf in its local area. The group applied on Form 1023-EZ, claiming charitable and…
IRS finds a title-holding "social club" that runs public bingo does not qualify under 501(c)(7)
The IRS determined that an organization did not qualify as a tax-exempt social club under section 501(c)(7) for the years examined. The group had never filed an exemption application; it…
IRS revokes a charity's 501(c)(3) status after it sold its assets but never formally dissolved
The IRS revoked an organization's recognition as a tax-exempt charity under section 501(c)(3). The group had wound down its affairs: it sold all of its property, collected the sale proceeds in…
IRS denies 501(c)(4) status to a condominium homeowners' association
A homeowners' association organized as a nonprofit mutual benefit corporation applied on Form 1024 to be recognized as a tax-exempt social welfare organization under section 501(c)(4). Its only…
IRS treats a large trust grant to a theater company as an "unusual grant," protecting its public-charity status
A public charity keeps that status only if it draws a broad base of public support; one very large gift can distort the math and threaten the charity's classification. To handle that, the tax rules…
IRS denies 501(c)(4) social-welfare exemption to a baseball umpire association that mainly serves its members
A membership organization of baseball umpires applied to be recognized as a tax-exempt social welfare organization under IRC § 501(c)(4). It recruits, trains, and assigns umpires as independent…
IRS denies 501(c)(3) status to a climate-product venture that is primarily commercial
An organization applied (on the streamlined Form 1023-EZ) to be recognized as a charity under IRC § 501(c)(3), describing a mission around global cooling, carbon sequestration, and climate-friendly…
IRS treats a large multi-year grant to an arts public charity as an "unusual grant," protecting its public-support status
A small arts public charity, classified under IRC § 509(a)(2), asked the IRS whether a large grant it expected to receive would count as an "unusual grant." The charity advocates for a particular…
IRS denies 501(c)(4) status to a manufactured-home community's homeowners group as private-benefit, not social welfare
A homeowners group from a manufactured-home community applied to be recognized as a tax-exempt social welfare organization under IRC § 501(c)(4), and the IRS said no. The homeowners own their…
IRS denies 501(c)(4) status to a member-funded burial-benefit association as a mutual self-interest group
An unincorporated mutual-aid association rooted in a particular ethnic community's burial custom applied for tax exemption as a social welfare organization under IRC § 501(c)(4). The group collects…
IRS denies 501(c)(7) social-club status where lease and rental income from nonmembers is the club's main revenue
An organization that holds and manages property for a fraternal group applied to be recognized as a tax-exempt social club under IRC § 501(c)(7), and the IRS denied it. A § 501(c)(7) club is meant…
IRS revokes 501(c)(7) status of a women's cultural club whose investment income exceeded the limit on receipts from outside the membership
A women's club organized to promote cultural, intellectual, and civic activities was tax-exempt as a social club under IRC § 501(c)(7), and the IRS revoked that exemption. A § 501(c)(7) club is…
IRS denies 501(c)(3) status to an equine-events club because its horsemanship competitions serve a substantial recreational purpose
A club that runs equine speed events and horsemanship competitions applied for tax-exempt charitable and educational status under IRC § 501(c)(3) using the short Form 1023-EZ, and the IRS denied it.…
IRS denies 501(c)(25) title-holding status to a group organized as a self-proclaimed sovereign nation
An organization applied to be recognized as a tax-exempt title-holding entity under IRC § 501(c)(25), and the IRS denied it. A § 501(c)(25) organization exists for one narrow purpose: to acquire…
IRS denies 501(c)(7) status to a family landholding group living on product sales and oil-and-gas royalties
A group made up of the descendants of one ancestor, who own inherited land and meet once a year, applied to be recognized as a tax-exempt social club under IRC § 501(c)(7), and the IRS denied it. A…
IRS disqualifies a self-declared 501(c)(7) immigrant social club that lived on rental income from its building
A social club that served working-class immigrants had treated itself as tax-exempt under IRC § 501(c)(7) without ever getting a determination letter from the IRS ("self-declared" status). On audit,…
IRS denies 501(c)(4) status to a gated-community homeowners' association whose amenities are walled off from the public
A homeowners' association for a gated residential community applied for tax-exempt status as a social welfare organization under IRC § 501(c)(4). The association maintains private streets,…
IRS revokes 501(c)(3) status of a charity that never actually operated
A nonprofit had received IRS recognition as a § 501(c)(3) public charity, proposing an ambitious slate of programs (peer support and independent-living services, financial literacy for young adults,…
IRS disqualifies a self-declared 501(c)(7) social club whose bar, banquet-hall rentals, and bingo drew too much public income
A social club, tied to a local fraternal chapter, treated itself as tax-exempt under IRC § 501(c)(7) without ever getting a determination letter from the IRS ("self-declared" status) and filed Forms…
IRS revokes a foundation that a trade group used to pay member-only insurance and benefits
A § 501(c)(3) charitable foundation had been set up by a related trade group, a § 501(c)(6) professional membership organization (whose members included owners, trainers, and grooms in a particular…
IRS lets a church use the 15-year neighborhood-land rule so mortgaged land it is redeveloping isn't taxed as debt-financed property
A tax-exempt organization normally pays "unrelated business income tax" on income from property it bought with borrowed money (debt-financed property), even on rents that would otherwise be…
IRS denies 501(c)(3) status to a mutual-aid group that pays bereavement benefits to its own members
A membership group applied to be recognized as a tax-exempt charity under IRC § 501(c)(3), and the IRS denied it. The group's stated purpose was to support its own members when they lose an…
IRS denies 501(c)(6) business-league status to a weekly referral club that admits one member per profession
A business-networking group applied for tax-exempt status as a business league under IRC § 501(c)(6), and the IRS denied it. The group holds weekly meetings where members exchange business referrals…
IRS denies 501(c)(3) status to a parent-run homeschool cooperative as serving members' private interest
A parent-run homeschool cooperative applied to be recognized as a tax-exempt educational charity under IRC § 501(c)(3), and the IRS denied it. In the co-op, homeschooling parents volunteer as…
IRS denies 501(c)(3) status to a performing-arts nonprofit that failed the organizational test
A newly incorporated nonprofit focused on creating performances that explore the human experience and inspiring young artists applied for recognition as a tax-exempt charity using the short Form…
Herbal-supplement maker denied 501(c)(3) status under the commerciality doctrine
An organization that manufactures and sells an oral herbal supplement (and educates the public about the supplement's claimed health benefits) applied for 501(c)(3) charity status, and the IRS…
Soccer-referee association denied 501(c)(10) fraternal-society status for lacking a lodge system and fraternal activities
An organization that supplies certified referees to officiate youth and school soccer matches applied to be recognized as a tax-exempt domestic fraternal society under section 501(c)(10), and the…
IRS revokes a family private foundation run from the founders' home for inurement and self-dealing
The IRS revoked the tax-exempt status of a private foundation, effective January 1, 2016, after an audit found the foundation was operated for the private benefit of the married couple who ran it…
State chapter of a professional association denied 501(c)(3) status for serving members rather than exclusively educational purposes
A state chapter of a national professional association applied for 501(c)(3) charity status using the streamlined Form 1023-EZ, and the IRS denied it. The chapter serves professionals in a…
Veterans' organization denied 501(c)(3) status because a civic center for social events is a substantial nonexempt purpose
An organization already recognized as a tax-exempt veterans' group under section 501(c)(19) applied to also be recognized as a charity under section 501(c)(3), and the IRS denied it. The denial…
IRS revokes exemption for a fee-based building-code inspection organization
The IRS revoked the Section 501(c)(3) status of an organization that succeeded a for-profit building-code inspection and consulting business. The organization contracted with municipalities,…
Land and water-rights broker for a mining town denied 501(c)(6) business-league status
The IRS denied section 501(c)(6) business-league status to a nonprofit set up to help a community recover from the closure of a major local employer by facilitating transfers of that company's land…
Social club loses 501(c)(7) status after living on investment income from selling its clubhouse
The IRS revoked a men's social club's section 501(c)(7) exemption because too much of its income came from outside its membership. A tax-exempt social club may receive at most 35 percent of its…
Charity for disabled children's therapies revoked for stonewalling an audit and aiding the founder's family
The IRS revoked a small charity's section 501(c)(3) exemption after it repeatedly failed to respond to an audit and produce financial records. The organization had obtained exemption through the…
Charity revoked for running real-estate "bargain sales" instead of education, with inurement to its founder
The IRS revoked a nonprofit's section 501(c)(3) exemption after an examination found it was not operated for charitable or educational purposes. The organization claimed its primary activity was…
Social club loses 501(c)(7) exemption for too much nonmember income
The IRS revoked the section 501(c)(7) exemption of a social club that runs a clubhouse, swimming pool, and tennis courts, because too much of its income came from nonmembers. A tax-exempt social…
Adult recreational sports club denied 501(c)(3) exemption
The IRS denied section 501(c)(3) status to a recreational sports group made up of former players of a particular sport who gather about once a week to play. The denial became final because the group…
Veterans' post loses 501(c)(19) exemption for having too few veteran members
The IRS revoked the tax exemption of a veterans' post that had been recognized as a section 501(c)(19) organization under a national group ruling. To qualify under 501(c)(19), at least 75 percent of…
Open-source software worker cooperative denied 501(c)(3) exemption
The IRS denied section 501(c)(3) status to a nonprofit worker cooperative whose main activity is developing and distributing open-source software and related educational materials. The denial became…
Title-holding company loses its 501(c)(2) exemption for leasing property and running a bar
The IRS revoked a corporation's tax exemption as a section 501(c)(2) title-holding company. To qualify under 501(c)(2), an organization must be organized and operated exclusively to hold title to…
501(c)(3) exemption denied to a legal-profession networking group operated for substantial non-exempt purposes
An organization for members of the legal profession (its members include judges, professors, prosecutors, and private and in-house attorneys) applied for tax-exempt charity status under § 501(c)(3)…
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.