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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Retailer association denied charitable exemption
An association of retailers held quarterly meetings on marketing, personnel management, and product procurement. It also rewarded member businesses' customers with free picnics, parties, and golf…
Healthcare insurer denied charitable exemption
An organization planned to sell comprehensive healthcare insurance for a monthly premium and later develop healthcare facilities. Insurance premiums were projected to produce 94 percent of its…
Commercial production project denied charitable exemption
An organization proposed to train disabled people, particularly veterans, through paid positions on commercial production projects. It would own the resulting intellectual property, license…
Condominium association denied social-welfare exemption
A condominium owners association applied for exemption as a social-welfare organization under section 501(c)(4). It collected homeowners association and management fees and used them for building…
Breeding and showing association denied charitable exemption
An association already exempt under section 501(c)(5) asked to change its status to a charitable and educational organization under section 501(c)(3). Its articles authorized activities promoting…
Homeowners association denied charitable exemption
A homeowners association applied for recognition as a charitable organization under section 501(c)(3). Every lot owner in the subdivision was a member, and annual dues funded services such as snow…
Internet exchange point denied business-league exemption
A nonprofit internet exchange point sought exemption as a business league under section 501(c)(6). It connected members to shared switching infrastructure for internet traffic exchange and route…
Member death-benefit association denied social-welfare exemption
An association collected registration fees, annual dues, and per-member assessments to pay death benefits to the designated beneficiaries of deceased members. It also offered members free seminars…
For-profit hunting club denied social-club exemption
A for-profit corporation owned land where its shareholders could hunt, camp, ride off-road vehicles, snowmobile, and engage in conservation activities. It received no member income; all revenue came…
Food-truck scheduling association denied business-league exemption
A food-truck association sought exemption as a business league under section 501(c)(6). It lobbied governments, promoted vending locations, worked with event planners and suppliers, and offered…
Nonprofit grocery store denied 501(c)(3) exemption
A nonprofit planned to operate a grocery store in a blighted, low-income census tract that it described as a food desert. It intended to sell affordable nutritious food, accept donated groceries,…
Business referral group denied business-league exemption
An unincorporated association of professionals sought exemption as a business league under section 501(c)(6). Its members met weekly to learn about one another's businesses, exchange referrals, and…
Breed association denied 501(c)(3) exemption
An unincorporated breed association sought exemption under section 501(c)(3). Its activities included an annual show, other public events, a festival presentation, membership meetings, awards, and…
Death-benefit group denied social-club exemption
A group of close friends sought exemption as a social club under section 501(c)(7). Members paid monthly fees into a fund that made a fixed payment after a qualifying death involving a member,…
Business corridor group denied 501(c)(3) reclassification
A business corridor organization already exempt under section 501(c)(6) asked to qualify under section 501(c)(3). It held an annual anti-violence festival, organized business mixers, distributed…
Truck and tractor pull group denied 501(c)(3) reinstatement
An organization whose exemption had been automatically revoked sought reinstatement under section 501(c)(3). Its articles stated that it was formed for social and civic purposes and to host an…
Medical marijuana dispensary denied 501(c)(3) reinstatement
An organization whose exemption had been automatically revoked sought retroactive reinstatement under section 501(c)(3). Its articles and bylaws stated that it would dispense medical cannabis to…
Homeowners association denied social-welfare exemption
A homeowners association sought exemption as a social-welfare organization under section 501(c)(4). Membership was compulsory for homeowners inside a fenced area, and dues maintained streets,…
Commercial hog farm denied 501(c)(3) exemption
An organization proposed a self-sustaining hog farm that would use donated surplus or waste inputs, sell part of its output, and donate the balance to related charities. It expected its product to…
Fundraiser for one person's medical and burial expenses denied exemption
An unincorporated association applied for section 501(c)(3) status to raise funds for the medical costs and burial of one named person. The IRS concluded that paying a preselected individual's…
Legal-defense trust for one person denied exemption
A trust applied for section 501(c)(3) status to raise money for one named person's legal defense and possible bail or bond. The fund would remain active until that person was exonerated or exhausted…
Single-software user group denied business-league exemption
A membership organization held meetings and training for employees of businesses using one manufacturer’s software and shared user feedback with that manufacturer. The IRS concluded that its…
Sportsmen’s social club denied charitable exemption
A long-running sportsmen’s club conducted conservation, youth, hunter-safety, and habitat activities, but also maintained year-round recreational facilities and events for adult members. Its…
IRS denies charity status to member-benefit organization
An organization already recognized under section 501(c)(5) applied for recognition as a section 501(c)(3) charity. It provided death benefits and related assistance to the widows and orphans of…
IRS denies social-club exemption due to nonmember rental income
A fishing and conservation club applied for exemption as a social club under section 501(c)(7). It organized member fishing tournaments, but it also rented its clubhouse to members and nonmembers,…
Business networking group denied business-league exemption
A business networking organization limited membership generally to one representative from each business classification. Members held weekly meetings, delivered self-promotional presentations, and…
Fundraising website denied charitable exemption for insufficient operational detail
An organization applied for section 501(c)(3) status to operate a no-fee website supporting community fundraising campaigns. It planned to absorb payment-processing costs, publicize campaigns…
Exclusive-category networking group denied business-league exemption
A membership organization held weekly breakfast meetings where members discussed and promoted their businesses, along with outings and social events. Membership was generally limited to one…
IRS revokes mistaken charitable exemption for defective organizing documents
An organization had previously been treated as a section 501(c)(4) social welfare organization, but after that status was revoked, a secretary mistakenly filed Form 1023-EZ seeking section 501(c)(3)…
Business referral chapter denied social-welfare exemption
A business networking chapter sought exemption as a section 501(c)(4) social welfare organization. Members met weekly to deliver short business presentations, learn referral techniques, and help one…
IRS denies exemption to a general business networking group
A membership organization of professionals from different trades and businesses applied for exemption as a business league under section 501(c)(6). Members met weekly to exchange referrals and grow…
IRS denies exemption to an exclusive business referral group
An exclusive-category networking group admitted one member from each type of business and operated weekly breakfast meetings and periodic mixers. Its members exchanged leads and referrals, presented…
IRS denies exemption because coffee shop operations serve a substantial commercial purpose
An organization planned to support Christian mission trips through grants to students and missionary organizations. It intended to fund those grants primarily by operating a public coffee shop and…
IRS revokes exemption after an organization mistakenly sought section 501(c)(3) status
An organization received section 501(c)(3) status through Form 1023-EZ after attesting that its governing documents contained the required purpose limitations and dissolution provisions. During…
IRS revokes exemption for failing the organizational and operational tests
An organization received section 501(c)(3) recognition through Form 1023-EZ, but an IRS examination later reviewed its governing documents and activities. The IRS found that the articles described…
Farmers' market denied agricultural organization exemption
An association of farmers and gardeners applied for exemption as an agricultural organization under section 501(c)(5). It operated a year-round farmers' market, charged vendors for space, assigned…
Restaurant denied section 501(c)(3) exemption for commercial operations
An organization sought retroactive reinstatement of section 501(c)(3) status after an earlier exemption was revoked for failing to file required returns. Its articles contemplated international…
Charity's support for an affiliated PAC would violate campaign and private-benefit rules
A section 501(c)(3) healthcare organization proposed to let its taxable subsidiary establish a political action committee. The charity would provide employees, facilities, administrative services,…
Fine-dining club denied section 501(c)(3) exemption
A membership organization applied for section 501(c)(3) status while planning quarterly fine-dining events for members interested in food and wine. Its articles did not limit its purposes to exempt…
Exemption revoked after disability-services organization became inactive
A nonprofit had been recognized under section 501(c)(3) to diagnose developmental disabilities and help affected people locate services. After government funding ended, its Forms 990 reported that…
Hospital exemption revoked after all assets were sold
A hospital had been recognized under section 501(c)(3) and was exempt from filing annual Forms 990 because it was affiliated with a government agency. It later sold all of its assets, stopped…
Facility-leasing organization denied charitable status
An organization bought and renovated a former church building, then leased it to religious and educational tenants and made it available for weddings, meetings, concerts, and other events. Almost…
Sliding-scale auto repair shop denied charitable status
An organization planned to operate an auto repair shop for the general public, using a sliding fee scale tied to household income. Some customers would pay normal market rates, the organization…
Police association denied fraternal-beneficiary exemption
A police association sought section 501(c)(8) status after its prior section 501(c)(4) status was automatically revoked for failing to file Form 990 for three consecutive years. It held meetings,…
Exemption revoked after organization failed to provide records
An exempt organization told the IRS that it had terminated. The IRS requested descriptions of its activities, financial statements, minutes, publications, a final return, a formal statement about…
Exemption revoked after organization failed to provide audit records
The IRS audited an organization that had received section 501(c)(3) status through Form 1023-EZ. The organization had not filed a Form 990-series return for the audited year and did not provide the…
Standard flash game income does not qualify for the bingo exception
A tax-exempt charity raised money through a game called standard flash, in which players opened pull-tab cards that could be instant winners, instant losers, or cards allowing later number-matching…
Title-holding company denied exemption because its income went to a nonexempt parent
A corporation held commercial real estate, collected rent from unrelated tenants, and distributed the net income to its sole member. That member was disregarded to a foreign organization that the…
Inactive private foundation loses section 501(c)(3) status
A private foundation reported no income or expenses on its annual returns, made no charitable contributions, and never carried out its planned scholarships, small-business assistance, or grants to…
Organization loses exemption after failing to provide audit information
A charitable organization had been recognized as exempt for a proposed summer camp serving abused, neglected, and abandoned teenagers. The IRS selected it for audit and repeatedly sought financial…
Veterans charity revoked for repeated excess-benefit transactions
A veterans charity operated rooming houses and provided transportation to medical appointments, but its president and another officer were domestic partners who controlled its bank accounts without…
Ministry loses exemption after its president used funds for personal expenses
A ministry conducted life coaching, prison ministry, athletic coaching, Bible study, and a daily fellowship call. Its founder and president had sole control of its only checking account, and the…
Organization loses exemption after failing to answer audit requests
An organization recognized under section 501(c)(3) was selected for an audit of a Form 990-N year and had not filed a Form 990-series return for another year identified in the report. The IRS sent…
Animal sanctuary foundation loses exemption after repeated failed audit contacts
The IRS revoked a foundation's section 501(c)(3) exemption after it could not verify that the organization continued to operate for exempt purposes. The foundation had described animal sanctuary,…
Exemption revoked because organizing documents failed the organizational test
The IRS revoked an organization's section 501(c)(3) exemption retroactively to its original effective date. The organization had used Form 1023-EZ and attested that its organizing document limited…
Motorcycle-event organization loses exemption for private benefit and nonexempt activity
The IRS revoked a motorcycle-event organization's section 501(c)(3) exemption after finding that it operated primarily for social activity and private benefit rather than charity. The organization…
Soccer referee placement service denied section 501(c)(3) exemption
An organization recruited, trained, mentored, scheduled, and paid independent soccer referees for local leagues under negotiated contracts. Its revenue came from league and association fees, and…
Industrial park association denied section 501(c)(4) exemption
An association formed to maintain and improve the common areas and shared facilities of a commercial and industrial park sought exemption under section 501(c)(4). Membership was limited to lot…
Advocacy group denied exemption after failing to detail political activity
An advocacy organization proposed educating voters, facilitating dialogue, identifying common ground, influencing elected officials, and supporting or opposing officials based on their response. The…
Benefit and social organization denied fraternal-society exemption
An organization provided sick and death benefits to active members, social activities to members, and event-facility rentals. It first sought social-club exemption and then changed its request to…
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.