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 denies Section 501(c)(3) status to an adjunct faculty mutual benefit group
An organization formed as a mutual benefit corporation applied for recognition as a Section 501(c)(3) charity. It promoted the professional treatment, economic welfare, and rights of adjunct faculty…
IRS denies Section 501(c)(3) status to a member golf course
An organization operating a golf course and clubhouse for members applied for recognition as a Section 501(c)(3) charity. Members and their families could use the course and reserve the clubhouse,…
IRS denies social welfare exemption for political campaign activity
An organization sought exemption as a social welfare organization under Section 501(c)(4). Its activities included advertisements opposing a political candidate, highlighting elected officials and…
Foreign regranting program qualifies under private-foundation rules
A private foundation planned to fund three foreign charities that would independently select local organizations for projects serving disadvantaged elders, children, teenagers, and other…
IRS denies exemption for funding founder-owned therapy provider
An organization proposed to pay for therapy when patients' insurance did not cover treatment. The only provider of that therapy in the state was a for-profit company solely owned by the…
IRS denies exemption for insufficiently documented downtown program
An organization raised funds to revitalize a city's central business district and made grants to landlords and businesses within that district. It also ran annual community events and made grants to…
IRS denies exemption for funding founder's education
An organization planned eventually to provide free health and wellness education and counseling, but its initial and primary activity was funding its founder's full-time professional education. It…
Cultural organization denied Section 501(c)(3) exemption
An organization applied for recognition as a Section 501(c)(3) charity to support a particular cultural community. Its stated activities included cultural exchange, traditions, language classes,…
Business-referral group denied Section 501(c)(6) exemption
A membership organization applied for exemption as a business league under Section 501(c)(6). Its members represented different types of businesses, met regularly to exchange referrals, tracked the…
Educational flight organization loses Section 501(c)(3) status
An organization had received Section 501(c)(3) status after describing educational flight training for children, teenagers, adults, and a low-income community. During an audit, it did not provide…
Family fundraising organization denied Section 501(c)(3) status
An organization applied for Section 501(c)(3) status to raise awareness of an injury and improve the quality of life of a specifically named individual and that individual’s family. It planned to…
Shooting organization fails the Section 501(c)(3) organizational test
An organization operated shooting competitions, practices, safety classes, and training facilities used by national competitors, a state agency, and local law enforcement. It was incorporated as a…
Medical fundraiser for one person denied exemption
An organization was formed to raise money for one named person's cancer-treatment expenses through benefit dinners, community donations, and crowdfunding. Its receipts and disbursements served that…
Member-benefit organization loses Section 501(c)(3) exemption
An organization claimed to provide financial help for medical and other needs, but membership was limited to members of a particular group and their families. Its articles did not limit it to exempt…
Homeowners association receives more time for Section 528 elections
A homeowners association inadvertently failed to file Form 1120-H elections for several taxable years. The IRS found that the association satisfied the standards for discretionary filing relief…
Social club loses exemption for public use and nonmember income
A Section 501(c)(7) social club operated a bar, gaming room, event space, and other recreational facilities that were open to the public. The club did not charge members dues or give them discounts,…
Excess investment income ends social club exemption
A Section 501(c)(7) club provided hunting, fishing, and outdoor activities to members and did not conduct activities with nonmembers. Its receipts also included dividends, interest, securities…
Fraternal and private-benefit activities end charity exemption
A fraternal organization claimed that its principal charitable activity was an annual scholarship fundraiser. Its records instead showed extensive member-focused operations, including lodge…
Fund for two named children denied charity exemption
A nonprofit corporation was formed to raise money for the care and education of two children whose father had died. It planned silent auctions, dinners, races, golf tournaments, and other…
Public golf receipts end social club exemption
A Section 501(c)(7) golf club opened its facilities to the general public after membership declined. It earned nonmember revenue from green fees, cart rentals, tournament food and drink sales, hole…
Defective articles and missing records end charity exemption
An organization obtained Section 501(c)(3) status through Form 1023-EZ after attesting that its organizing document met federal requirements. During an audit, state records showed that its articles…
No member social activity and excess investment income end exemption
An alumni organization claimed exemption as a Section 501(c)(7) social club. It had no property or member facility, held meetings virtually, and mainly published a twice-yearly newsletter, so…
Golf club loses Section 501(c)(7) status for serving the public
The IRS revoked a golf club's exemption under IRC § 501(c)(7). The club operated a golf course, restaurant, bar, pro shop, and event facilities that were open to the general public. It advertised…
Recurring nonmember income ends social club exemption
A Section 501(c)(7) club opened events and facilities to both members and nonmembers but did not separately track their receipts. It also reported dividends from only one of two investment accounts…
Inactivity and missing records cost a private foundation its exemption
A private foundation was formed to support science, technology, education, and related economic development. Its annual returns repeatedly reported no charitable activities, no qualifying…
Public bingo and rentals defeat social club exemption
A self-declared social club operated public bingo games and rented its facility mostly to nonmembers. It had no identified dues structure, little member income, and no other significant activities.…
No educational activity or records ends charity exemption
An organization obtained Section 501(c)(3) status through Form 1023-EZ after stating that it would conduct educational activities. During an audit, it provided incomplete information and did not…
Public hall rentals revoke social club status
A self-declared social club had three members, charged no membership dues, and rented its banquet hall and other facilities to the public. It advertised the hall and reported nonmember rental income…
Single-family home school serves private interests
An organization sought Section 501(c)(3) status as a school, but its only activity was operating a home school for the child of its two married directors. No other children attended, and the…
Investment income replaces social-club activity
A social club sold the building it had held for affiliated fraternal organizations and stopped conducting social activities. After the sale, investment income represented 100 percent of its gross…
Catering income revokes business club exemption
A private business club contracted with an outside catering corporation and received monthly payments that made up most of the club’s gross revenue. The club correctly reported the payments as…
Business promotion defeats historic-preservation exemption
An organization claimed that promoting a historic commercial area would combat community deterioration and preserve the neighborhood. Its actual activities consisted mainly of advertising local…
Undocumented dissolution revokes charity exemption
A charity filed articles of dissolution under state law but did not respond to the IRS examination. It did not file a final Form 990, provide dissolution documents to the IRS, describe the…
Long-inactive charity loses exemption
An organization obtained Section 501(c)(3) status through Form 1023-EZ but later told the IRS that it had never truly been active and had no plans to reactivate. It did not provide its organizing…
Nonmember income costs social club its exemption
The IRS revoked a social club's Section 501(c)(7) exemption after investment and rental income exceeded the 35% limit on investment and nonmember income in four of five examined years. The…
Inactivity and missing dissolution records trigger revocation
An education-focused organization stopped conducting exempt activities but retained land and did not complete or substantiate dissolution. The IRS repeatedly requested stamped dissolution articles,…
Block beautification group fails charitable tests
A nonprofit formed to beautify and maintain a particular city block did not qualify under Section 501(c)(3). Its purpose and dissolution clauses expressly included Section 501(c)(4) purposes, so its…
Public rentals revoke social club exemption
A social club maintained a building used as rental investment property and as a meeting place for a Section 501(c)(8) organization. It advertised the facilities to the public, and nonmember facility…
Private homeowners association loses exemption
A gated homeowners association classified as a private foundation did not qualify under Section 501(c)(3). Its articles stated the nonexempt purpose of operating a homeowners association and…
Public bingo and dinners revoke club exemption
A social club opened weekly bingo, dinner events, and substantial portions of its facilities to the public, advertised bingo publicly, and leased land to a for-profit solar company. Its recurring…
Annual cultural festival did not support charity exemption
An organization recognized under Section 501(c)(3) operated an annual one-day cultural New Year festival as its sole activity. The festival featured performances and contests, charged admission and…
Property owners’ association denied business-league exemption
A commercial property owners’ association applied for exemption as a business league under Section 501(c)(6). Membership was compulsory for owners in one commercial development, and the association…
Member social club lost Section 501(c)(4) exemption
An organization created through the efforts of several veterans’ organizations was exempt as a social-welfare organization under Section 501(c)(4). Members of the related organizations automatically…
Inactive supporting organization lost charity exemption
A Type I supporting organization had no income, expenses, bank account, assets, liabilities, or activities after formation. It made no payments to its supported organization and provided no services…
Charity lost exemption after ignoring audit requests
A cultural education organization was selected for an audit of its Form 990-N filing and exempt activities. The IRS mailed multiple information requests, called the organization and its…
Student-loan lottery denied exemption because it primarily benefited private winners
An organization sought IRC § 501(c)(3) status for a student-loan lottery tied to prize-linked savings accounts. Participants would deposit money, winners would be selected randomly, and investment…
Family-run care organization denied exemption for organizational defects and private benefit
A family-run organization sought reinstatement of IRC § 501(c)(3) status after its prior exemption was automatically revoked for failing to file required returns. Its filed articles allowed any…
Automobile club denied exemption because social activities predominated
An automobile membership club sought recognition as a charitable and educational organization under IRC § 501(c)(3). Its governing documents promoted ownership and enjoyment of a particular car, and…
Medical marijuana membership dispensary denied exemption
A membership organization sought exemption under IRC § 501(c)(3) for operating a medical marijuana dispensary and cultivating and distributing cannabis to members. The organization charged…
Student loan repayment lottery denied exemption
An organization sought exemption under IRC § 501(c)(3) for a program that collected donations and application fees and randomly selected participants to receive payments toward student loan debt.…
Adult softball team denied exemption
An adult women's softball team sought exemption under IRC § 501(c)(3). Its articles of incorporation stated neither an exempt purpose nor how assets would be distributed upon dissolution. The team's…
Business referral group denied social welfare exemption
A professional networking chapter sought exemption as a social welfare organization under IRC § 501(c)(4). Its members promoted one another through referrals, met weekly, and paid dues that funded…
IRS denies exemption to a social and recreational hobby group
An unincorporated association of friends sought tax-exempt status for activities involving education, making, and tasting in redacted subject areas. Its meetings included guest speakers and…
IRS denies exemption to a fund benefiting preidentified employees
An organization used profits from sales in a workplace lunchroom to make fixed payments to employees who belonged to a particular union and experienced a redacted event. The IRS found that its…
IRS denies business-league status to a cooperative retail gallery
A member organization operated a seasonal retail gallery that sold members' handcrafted goods, retained part of the proceeds, and paid the remainder to each seller. It also provided bookkeeping,…
IRS denies business-league status to a football-official placement service
A membership organization recruited, trained, evaluated, and assigned football officials to games for local school districts. It collected the districts' payments and distributed compensation to the…
IRS denies charitable status to a recreational community festival
An organization conducted an annual community festival featuring a beauty pageant, parade, tournaments, a run, a car show, fireworks, games, vendors, children's activities, and music. Its articles…
IRS denies charitable status to a recreational vehicle club
A nonprofit vehicle club sought exemption for promoting recreation and preserving or restoring older vehicles. Its main activities were an annual vehicle show, another annual vehicle gathering, and…
IRS denies charitable status to an industry member association
An industry association sought charitable and educational exemption while serving owner-operators and related businesses through paid memberships. Its objectives included promoting professionalism…
IRS denies charitable status to an adult recreational soccer league
A nonprofit corporation operated an adult soccer league funded entirely by participant registration fees. Its articles described its purpose as providing physical recreation and fun, while also…
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.