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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501(c)(3) exemption denied to an applicant that submitted implausible statements and apparently inauthentic documents
An organization that described itself as a trust engaged in religious and humanitarian activities applied for recognition as a tax-exempt charity under § 501(c)(3). The IRS denied the application.…
IRS denies 501(c)(3) status to a group funding cannabis and psychedelic research because it promotes federally illegal activity
A nonprofit corporation applied for 501(c)(3) status to promote the medical and mental-health benefits of cannabis and psychedelic plants (psilocybin, peyote, ayahuasca, ibogaine), to fund research…
IRS denies 501(c)(3) status to a sports-and-arts club operated for substantial recreational and social purposes
An organization applied for 501(c)(3) charitable status using the streamlined Form 1023-EZ, describing its mission as promoting sports and arts, running training and coaching programs, and…
IRS revokes a 501(c)(7) social club's exemption for taking too much oil-and-gas royalty (non-member) income
A tax-exempt social club under IRC § 501(c)(7) leased part of its property to an exploration company and, for years, collected substantial oil-and-gas royalty income on a monthly basis. Section…
IRS revokes a social club's § 501(c)(7) status because investment income exceeded the 35% limit and it stopped operating
A membership social club had been recognized as tax-exempt under Section 501(c)(7), which covers clubs operated substantially for the pleasure and recreation of their members. A social club can take…
IRS revokes a self-declared 501(c)(3)'s exemption for funneling contractor donations into cash grants to individual homeowners (private benefit)
An organization that called itself a nonprofit public benefit corporation obtained streamlined 501(c)(3) recognition in 2016 by filing Form 1023-EZ and attesting that it was organized and operated…
IRS revokes a public charity's § 501(c)(3) status after it ignored an audit into suspected inurement and improper fundraising
A public charity recognized as tax-exempt under Section 501(c)(3) (it had been approved as a 509(a)(1)/170(b)(1)(A)(vi) public charity through a streamlined Form 1023-EZ application) was selected…
IRS disqualifies a self-declared § 501(c)(4) social welfare group that ran a for-profit business and benefited its president
An organization had treated itself as a tax-exempt social welfare group under Section 501(c)(4), which allows exemption for civic leagues operated exclusively to promote social welfare (the common…
IRS revokes a charity's § 501(c)(3) status for failing to produce records for an audit
A small charity that had been recognized as tax-exempt under Section 501(c)(3) (it had applied using the streamlined Form 1023-EZ) was picked for a routine audit. The IRS mailed a series of…
IRS denies § 501(c)(7) social-club status to a food buying club
A group that runs a food buying club applied to be recognized as a tax-exempt social club under Section 501(c)(7), and the IRS said no. Section 501(c)(7) is for clubs organized for pleasure and…
IRS denies § 501(c)(6) business-league status to an angel-investor network
An invitation-only angel-investor network applied to be recognized as a tax-exempt business league under Section 501(c)(6), and the IRS said no. The group recruits accredited investors as members,…
IRS denies § 501(c)(3) status to a commercial design business
A one-person organization applied for recognition as a charity under Section 501(c)(3), and the IRS said no. Its main activity was creating designs for clients' homes for a per-client fee (based on…
IRS denies § 501(c)(4) status to a group running an IRC 105-plan loan and "Social Security solvency" scheme
An organization applied to be recognized as a tax-exempt social welfare organization under Section 501(c)(4), and the IRS said no. The group had a two-part plan. First, it would lend money to…
IRS denies 501(c)(3) status to a soccer team's independent supporters' club
A membership group applied for tax-exempt charity status under 501(c)(3), describing itself as an independent supporters' group for a soccer team (referred to as C). Its activities center on the…
IRS denies 501(c)(3) status because the applicant never documented what it actually does
An organization applied for tax-exempt charity status under 501(c)(3) using the short Form 1023-EZ, describing its mission as serving "religious and funeral purposes." The Form 1023-EZ is mostly a…
IRS denies 501(c)(7) social-club status to a corporation running a seasonal trailer park
A corporation applied for tax-exempt status as a 501(c)(7) social club. It owns and operates a seasonal trailer park in which each mobile-home site corresponds to a share of the company's stock, so…
IRS denies 501(c)(6) business-league status to a single-vendor customer user group
An organization applied to be recognized as a tax-exempt "business league" under 501(c)(6). It operates as the customer and user community for the products of one for-profit technology company…
IRS denies 501(c)(3) status to a health care sharing ministry that operates like a commercial insurance business
A startup applied for recognition as a tax-exempt charity under 501(c)(3) so it could run a "health care sharing ministry," a program where members pay a monthly "share" into a common resource that…
Accountable care organization denied Section 501(c)(4) status
An accountable care organization owned by a Section 501(c)(3) health system asked to be recognized as a Section 501(c)(4) social-welfare organization. It coordinated patient care under the federal…
IRS denies 501(c)(3) status to a cannabis-sacrament church because its worship uses a federally illegal drug
A group applied to be recognized as a tax-exempt church under 501(c)(3). Its stated purpose is to advance a religion whose worship treats consecrated cannabis as a sacrament, comparable to how the…
IRS denies 501(c)(3) status to a fund that gives college scholarships to all children of a cooperative's employees, with no need or merit test
An organization applied to be recognized as a tax-exempt charity under section 501(c)(3). Its only activity was giving college scholarships to the children of employees of a particular cooperative,…
Late relief to revoke a 501(h) lobbying election, effective retroactively
A public charity had earlier filed Form 5768 to make a section 501(h) election, which swaps the vague "no substantial part" limit on lobbying for a dollar-based expenditure test. It later decided…
Final adverse determination denying 501(c)(3) exemption to an off-highway-vehicle recreation club
An off-highway-vehicle (OHV) club applied for recognition as a tax-exempt charity under § 501(c)(3), using the streamlined Form 1023-EZ. The IRS denied it. To qualify, an organization must pass both…
Final adverse determination denying 501(c)(3) exemption to a shopping-center merchants' association
A membership group made up of the businesses in a shopping-center area applied for recognition as a tax-exempt charity under § 501(c)(3), using the streamlined Form 1023-EZ. The IRS denied it. To…
Final adverse determination revoking a 501(c)(7) social club's exemption for excessive nonmember income
A fraternal and social membership club had been treating itself as tax-exempt under § 501(c)(7) as a self-declared exempt organization (it never filed Form 1024). On audit the IRS found the club…
Final adverse determination denying 501(c)(3) exemption to an open-source wireless-network organization
An organization applied for recognition as a tax-exempt charity under § 501(c)(3), and the IRS denied it. The group was formed to develop and promote open-source software for a decentralized…
Final adverse determination denying 501(c)(3) exemption to a university alumni social and networking club
A local alumni group affiliated with a university applied for tax-exempt charity status under § 501(c)(3) using the streamlined Form 1023-EZ, and the IRS denied it. The group's stated mission was to…
Final adverse determination denying 501(c)(3) exemption to a community recreational sports club
A community sports club applied for tax-exempt charity status under § 501(c)(3) using the streamlined Form 1023-EZ, and the IRS denied it. The club fielded youth and adult teams, ran leagues and…
Final adverse determination revoking a social club's 501(c)(7) exemption for too much non-member income
A tax-exempt social and recreation club described in § 501(c)(7) had its exemption revoked because too much of its income came from outside its membership. Social clubs are exempt only if they are…
Final adverse determination revoking a charity's 501(c)(3) exemption for not responding to an audit
A charity recognized under § 501(c)(3), which had described itself as running a summer camp program for abused, neglected, and abandoned teens, lost its tax-exempt status because it did not…
Final adverse determination revoking a 501(c)(3) exemption for an unanswered audit and a missing dissolution clause
A small charity that had obtained § 501(c)(3) status through the streamlined Form 1023-EZ application lost that status after an examination. The IRS sent a long series of letters and made repeated…
Final adverse determination revoking a 501(c)(3) charity's exemption for failing to substantiate that its emergency-relief spending served exempt purposes
A small charity that had obtained § 501(c)(3) status through the streamlined Form 1023-EZ application lost that status after an examination. The organization said its purpose was emergency…
Final adverse determination revoking a 501(c)(3) supporting organization's exemption because it never became operational
A nonprofit that had been recognized as a § 501(c)(3) organization, and classified as a Type I supporting organization under § 509(a)(3), lost its exemption because it never actually operated. The…
Final adverse determination revoking a 501(c)(3) exemption, back to its start, for a members-only military social organization that failed both the organizational and operational tests
An organization that had obtained § 501(c)(3) status through the streamlined Form 1023-EZ application lost that status, and lost it retroactively to the day the exemption began. In substance the…
Final adverse determination revoking a 501(c)(3) exemption, back to its start, because the organizing document failed the organizational test
A nonprofit that had obtained § 501(c)(3) status through the streamlined Form 1023-EZ application lost that status retroactively to the day it began. On its Form 1023-EZ the organization had…
Final adverse determination revoking a Type III supporting organization's 501(c)(3) exemption for becoming inactive after its supported organization went bankrupt
A charity that had been recognized as a § 501(c)(3) organization and classified as a Type III (non-functionally integrated) supporting organization under § 509(a)(3) lost its exemption after it…
Final adverse determination revoking a private foundation's 501(c)(3) exemption for private inurement to its sole trustee
A private non-operating foundation, created under a person's will to support the arts and provide scholarships to musicians, composers, and lyricists, lost its § 501(c)(3) exemption for private…
Final adverse determination revoking a 501(c)(4) civic league's exemption after it stopped operating
A social welfare organization exempt under § 501(c)(4), organized as a local post with officers such as a Commander and an Alternate Treasurer and affiliated with a state and national parent under a…
202150034: IRS revokes a veterans charity's 501(c)(3) status for inurement, finding its two officers skimmed solicited cash to fund gambling
A small charity said it helped veterans by running sober-living rooming houses and giving out basic necessities, funded by "bucket" cash solicitations outside retail stores. On audit, the IRS…
202150033: IRS revokes a ministry's 501(c)(3) status for inurement after its president used the organization's account for personal spending
A one-person ministry doing life coaching, mentoring, Bible study, and athletic coaching lost its tax-exempt charity status. The organization's founder and president had sole control of its single…
202150032: IRS revokes a fraternity house corporation's 501(c)(7) social club status because all of its income came from rent and investments, not members
A tax-exempt social club under Internal Revenue Code § 501(c)(7) is meant to be a members' club for pleasure and recreation, supported mainly by member dues, fees, and assessments. Federal law (P.L.…
202150031: IRS denies 501(c)(3) status to a family fund that covers funeral and emergency costs for the descendants of one ancestor
A membership fund applied to be recognized as a tax-exempt charity under Internal Revenue Code § 501(c)(3). Its members were the blood-related male descendants of a single ancestor, and the fund's…
202150030: IRS revokes a charity's 501(c)(3) status after it stopped filing returns and did not respond to the audit
A public charity recognized under Internal Revenue Code § 501(c)(3) lost its exemption for the simplest of reasons: it stopped filing its annual return and never responded to the IRS. Every exempt…
202150029: IRS revokes a charity's 501(c)(3) status after it ignored the audit and never filed its returns
A small charity that had been recognized as tax-exempt under Internal Revenue Code § 501(c)(3) lost that status because it went silent. The organization had obtained exemption through the…
202150028: IRS revokes a homeowners' association's 501(c)(4) status for serving its members, not the community, and for ignoring the audit
A homeowners' association that had ended up treated as a tax-exempt "social welfare" organization under Internal Revenue Code § 501(c)(4) lost that status for two independent reasons. First, it…
202150027: IRS revokes a defunct diagnostic charity's 501(c)(3) status for failing both the organizational and operational tests and not producing records
A charity originally recognized under Internal Revenue Code § 501(c)(3) to run a diagnostic center for people with developmental disabilities lost its exemption after it effectively stopped…
202150026: IRS revokes a cemetery association's 501(c)(3) status because running a cemetery is not a charitable purpose
A cemetery association that had obtained recognition as a charity under Internal Revenue Code § 501(c)(3) through the streamlined Form 1023-EZ lost that status on audit, because operating a cemetery…
202150025: IRS revokes a terminated charity's 501(c)(3) status after it stopped responding and never filed its final return
A charity recognized under Internal Revenue Code § 501(c)(3) told the IRS it had terminated, but then never wrapped things up on paper, so the IRS revoked its exemption. During the examination the…
202150024: IRS disqualifies a hunting club's 501(c)(7) status because oil and gas royalties, not membership, drive its income
A social club, a hunting and shooting club that also does firearm-safety education and land conservation, had never gotten an IRS determination letter but had filed for years as a self-declared…
202150023: IRS revokes a social club's 501(c)(7) status for recurring nonmember income from renting apartments above its clubhouse
A social club recognized as tax-exempt under Internal Revenue Code § 501(c)(7) lost that status because too much of its money came from outside its membership. A § 501(c)(7) club must be operated…
202150022: IRS revokes a defunct fraternity chapter's 501(c)(7) status: no members for a decade, income only from investments
A local chapter of a national fraternity that had been recognized as a tax-exempt social club under Internal Revenue Code § 501(c)(7) lost that status because it no longer functioned as a club at…
202150021: IRS revokes a charity's 501(c)(3) status after it never produced records for the audit despite months of attempted contact
A public charity recognized under Internal Revenue Code § 501(c)(3) through the streamlined Form 1023-EZ lost its exemption because the IRS could never complete an examination of it. Over many…
202150020: IRS denies 501(c)(3) status to an ethnic community mutual-aid group that mainly pays benefits to its own members
A mutual-aid association organized around an ethnic community applied for recognition as a tax-exempt charity under Internal Revenue Code § 501(c)(3), and the IRS denied it because the group mainly…
202150019: IRS revokes a motorcycle festival charity's 501(c)(3) status for operating primarily for private benefit
A charity had been recognized under Internal Revenue Code § 501(c)(3), stating in its exemption application that it would hold convention-style motorcycle rallies to raise money for other…
202150018: IRS revokes an inactive charity's 501(c)(3) status for failing to produce records
A small charity had been recognized as tax-exempt under Internal Revenue Code § 501(c)(3) after filing the streamlined Form 1023-EZ application. When the IRS selected it for audit, the organization…
IRS revokes a charity's 501(c)(3) status for failing to produce records for an audit
A small organization recognized as a 501(c)(3) charity was selected for audit and then went silent. The IRS repeatedly mailed and called, but the group never produced the records needed to show it…
IRS revokes a hospital's 501(c)(3) status after it sold its assets and stopped operating
A tax-exempt hospital sold all of its assets and stopped providing hospital services under its own name. After the sale, the corporate entity conducted no activities at all. It never filed articles…
IRS revokes a private foundation's 501(c)(3) status for never operating and serving private interests
A private foundation set up to fund small businesses and charities never actually did any charitable work. Houses tied to the founder's family were put in the foundation's name but kept running…
IRS revokes a housing charity's 501(c)(3) status for private inurement and failure to produce records
An organization formed to house and train homeless, needy, and disabled people lost its 501(c)(3) exemption after an audit uncovered signs that its founders were using it for private benefit. Bank…
IRS revokes a squadron morale club's 501(c)(3) status for non-exempt social purpose and failure to produce records
An organization set up to improve the health, welfare, and morale of members of a specified military work unit lost its 501(c)(3) exemption. Its main activities were social and recreational, such as…
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.