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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Marketing consultancy denied section 501(c)(3) status
An organization sought section 501(c)(3) status to provide business-development and marketing consulting, principally for nonprofits and public-works organizations. The IRS found that its services…
Missing organizing provisions caused exemption revocation
An organization received section 501(c)(3) status after attesting on Form 1023-EZ that its organizing document contained the required limits on purpose and disposition of assets at dissolution.…
Commercial medical equipment business lost exemption
A section 501(c)(3) organization operated two off-premises stores that sold and rented durable medical equipment to the general public at competitive commercial prices. Although it offered charity…
Missing organizing documents caused exemption revocation
An organization obtained section 501(c)(3) status through Form 1023-EZ after attesting that its organizing document contained the required limits on purpose and disposition of assets at dissolution.…
Soccer referee association denied section 501(c)(6) exemption
An association of soccer referees applied for exemption as a business league under section 501(c)(6). It trained and evaluated referees, but its primary activity was scheduling members for games,…
Charity exemption retroactively revoked for misstatements, lobbying, and illegal activity
The IRS retroactively revoked a corporation's section 501(c)(3) exemption after finding that its original application materially misstated how it would operate. The examination report said the…
Dissolving foundation's asset transfer qualifies as an unusual grant
A publicly supported charity serving injured special-operations veterans asked whether it could exclude a large transfer from its public-support calculation as an unusual grant. A dissolving…
Family-specific orphan fundraiser denied section 501(c)(3) status
An unincorporated association applied for section 501(c)(3) status to hold a fundraiser for five children from one family after both parents died. The planned event would use all raised funds to…
Gated homeowners association denied section 501(c)(4) exemption
A gated homeowners association sought recognition as a tax-exempt social welfare organization under section 501(c)(4). Its activities included maintaining private roads, common areas, recreational…
Sponsoring charity loses exemption over donor-directed funds and private benefit
The IRS revoked a sponsoring organization's section 501(c)(3) exemption after examining its ministry projects, benevolence programs, operating projects, donor-advised funds, and minister retirement…
Charity loses exemption after failing to provide records for audit
The IRS revoked a charity's section 501(c)(3) exemption after it repeatedly failed to provide records requested for an audit of its Form 990-N filing. The organization did not establish that it…
Foster-care agency loses exemption for private inurement
The IRS revoked a foster-family agency's section 501(c)(3) exemption after finding that it no longer operated exclusively for exempt purposes and allowed earnings to benefit insiders. The chief…
IRS revokes a small charity's 501(c)(3) status after it would not open its records
This is a final IRS letter revoking a small organization's tax-exempt status under Internal Revenue Code section 501(c)(3). The group had been recognized as exempt only recently (it applied on the…
Charity loses exemption after failing to provide audit records
The IRS revoked an organization's section 501(c)(3) exemption because it did not respond to repeated requests for information needed to audit its activities and operations. The organization had…
Charity loses exemption after failing to document insider transactions
The IRS revoked a charity's section 501(c)(3) exemption after it failed to provide records addressing possible private inurement and private benefit. The organization said its purpose was to house…
Organization loses exemption after failing to provide records
The IRS revoked an organization's section 501(c)(3) exemption because it did not provide records needed to examine its continued qualification. The IRS requested descriptions of its activities,…
Hospital moves from supporting-organization status to section 509(a)(2)
The IRS changed a hospital's public-charity classification from a section 509(a)(3) supporting organization to a section 509(a)(2) organization, while leaving its section 501(c)(3) exemption intact.…
Social club loses exemption after investment income exceeds the limit
The IRS revoked a social and recreation club's section 501(c)(7) exemption because too much of its gross receipts came from outside its membership. The club promoted cultural, social, civic,…
Foreclosure-referral organization denied 501(c)(3) exemption
An organization that assisted homeowners facing foreclosure applied for recognition under section 501(c)(3). The IRS denied exemption because the organization mainly collected intake information and…
Charity lost exemption after failing to substantiate its operations
A charity recognized under section 501(c)(3) reported receiving cash donations and making emergency-assistance payments, but it did not provide receipts, canceled checks, bank statements, or enough…
Inactive charity lost its section 501(c)(3) exemption
A public charity formed to support rural development, youth empowerment, and people in poverty stopped operating, had no income or assets during the examination year, and was administratively…
Family-run religious organization lost exemption for private benefit
A religious organization operated from a home garage, and its congregation consisted primarily of the founder-pastor’s immediate and extended family. The IRS found that members made tithes to the…
Family genealogy organization denied charitable exemption
An organization formed to collect and preserve one family’s genealogy, connect relatives, maintain a family-history website, and produce a family cookbook applied for recognition under section…
Historic housing cooperative denied charitable exemption
A nonprofit housing cooperative owned and maintained a residential complex designated as a National Historic Landmark. Members bought shares tied to occupancy rights, paid assessments covering…
Blockchain and token enterprise denied charitable exemption
An organization applied for section 501(c)(3) status claiming that it would research rising healthcare costs and publish information for consumers, providers, and policymakers. Its websites and…
Recreational roller derby team denied charitable exemption
A roller derby organization promoted women’s health, social interaction, community service, and participation in the sport. Most of its time was devoted to practices and recreational competition,…
Round-up donation app failed to establish charitable operation
An organization proposed an app and website that would link to users’ payment cards, round purchases up to the next dollar, hold the added amounts in organization-owned accounts, and later…
Homeowners association gets late-filing relief to elect Section 528 treatment for several years
A residential real estate management association can elect, year by year, to be taxed under Section 528, which lets a qualifying homeowners association be taxed only on its non-exempt-function…
501(c)(3) denied to a group subsidizing THC/CBD-medication patients because its purpose furthers a federally illegal activity
An organization applied for 501(c)(3) charity status to give financial help (living and other expenses) to financially disadvantaged patients who use THC and CBD (cannabis-derived) medications, plus…
Dormant charity loses 501(c)(3) status for showing no activity and keeping no records
The IRS revoked the 501(c)(3) exemption of an essentially dormant charity that could not show it was doing anything. To keep exemption, an organization must pass the operational test, engaging…
Wellness-practitioner cooperative denied 501(c)(3) status for serving members' private interests
The IRS denied 501(c)(3) exemption to an organization that ran a shared-facility cooperative for wellness practitioners, artists, and educators, concluding it operated mainly for the private benefit…
Retirement-community residents' association loses 501(c)(3) status for serving residents' private interests
The IRS revoked the 501(c)(3) exemption of a residents' association at a retirement community because its activities primarily served the private interests of the residents rather than the public.…
"Pay-what-you-want" café foundation loses 501(c)(3) status as a substantial commercial business
The IRS revoked a foundation's 501(c)(3) exemption because its main activity was running "pay-what-you-want" cafés that looked and operated like ordinary restaurants rather than a charity. To be…
Rural golf club loses 501(c)(7) exemption because most of its money came from the public
A social club exempt under section 501(c)(7), a small rural nine-hole golf club with a bar, restaurant, and gaming (pull-tab) operation, lost its exemption because it took in too much money from…
Charity set up to fundraise for one named accident victim is denied 501(c)(3) status
The IRS refused to recognize an organization as tax-exempt under section 501(c)(3) because it existed only to raise money for a single, named individual and his family. To qualify, an organization…
Social club loses 501(c)(7) exemption for renting its hall to the public past the 15% limit
A social club exempt under section 501(c)(7), a heritage/fellowship club that owned an event hall, lost its exemption because too much of its money came from renting that hall to the general public.…
Cancer charity loses 501(c)(3) status for running as a family business and inflating gift-in-kind reporting
The IRS revoked the tax-exempt status of a charity that had been recognized under section 501(c)(3) to give financial aid to needy cancer patients. To keep exemption, an organization must be…
IRS denies 501(c)(3) status to a scholarship-and-columbarium conduit that mainly benefits a related for-profit
To be tax-exempt under section 501(c)(3), an organization must be operated exclusively for charitable or educational purposes and must serve public rather than private interests; even one…
Assets absorbed in a merger qualify as an "unusual grant," protecting public-charity status
A public charity keeps its "publicly supported" status only if it passes a math test: enough of its money must come from the general public rather than from a few large donors. A single huge gift…
501(c)(3) exemption revoked back to day one because the articles never met the organizational test
To be a section 501(c)(3) charity, an organization must pass an "organizational test": its founding document (its articles of incorporation) must limit its purposes to exempt purposes and must…
501(c)(6) business league loses exemption for not producing records or filing returns
A business league recognized as tax-exempt under section 501(c)(6) lost that status because it stopped cooperating with the IRS. Exempt organizations must keep adequate books and records under…
501(c)(3) exemption revoked after the organization went dormant for years
A nonprofit that had been recognized as tax-exempt under section 501(c)(3) lost that status because it stopped operating. The organization was originally formed to provide dental care and to train…
501(c)(7) social club loses exemption for too much nonmember income and missing records
A social club that had been recognized as tax-exempt under section 501(c)(7) lost that status after an IRS examination. Such clubs must be organized and operated mainly for the pleasure and…
501(c)(3) exemption denied to a lobbying "action organization"
A membership association focused on a universal emergency telephone number (911-type service) applied to be recognized as a tax-exempt charity under Internal Revenue Code § 501(c)(3). The group was…
501(c)(3) exemption revoked for not keeping records or responding to the IRS
A tax-exempt § 501(c)(3) organization has to keep adequate books and records (Internal Revenue Code § 6001), file annual information returns (§ 6033), and let the IRS examine its activities. Here…
501(c)(3) exemption revoked; articles never limited purpose to exempt purposes
A § 501(c)(3) organization must be "organized exclusively" for exempt purposes, which means its founding document (here, its articles of incorporation) has to limit the organization to charitable or…
501(c)(3) exemption revoked for having no valid organizing document
To be tax-exempt under Internal Revenue Code § 501(c)(3), an organization must pass both an "organizational test" (its founding document must limit it to exempt purposes and dedicate its assets to…
Charity lost exemption after serving its founders' private interests
An organization formed to provide and maintain housing for its founders' adopted special-needs children. It raised money and used its funds to add space to the founders' personal residence, where…
Business property association failed the social-welfare test
A nonprofit association maintained common areas and building exteriors for business owners in a commercial shopping center. Membership depended on owning a lot, and assessments were allocated…
Social club lost exemption after recurring nonmember income exceeded the limit
A social and recreation club operated golf and other member facilities but also earned income from nonmembers and a cell-tower easement. The IRS found that nonmember income consistently exceeded the…
Professional association lost charity status but received nonretroactive relief
A national organization and its regional subordinates had been recognized as a § 501(c)(3) public charity and covered by a group exemption. Its activities included professional standards,…
Inactive alternative-fuel coalition lost charity status
An organization was formed to reduce petroleum consumption by promoting alternative-fuel vehicles and related programs. It had been recognized under § 501(c)(3), but its representative reported that…
Baseball-support group primarily benefited a for-profit team's players
An organization said it would support baseball, community relations, youth tickets, education, and preservation activities. Its financial records instead showed substantial spending on players of a…
Automatic funeral benefits for members served private interests
A membership organization collected one-time fees and paid funeral expenses when a member or family member died. The payments were automatic, with no qualification or review for financial need. The…
Auto-repair purchasing group provided particular services to members
An organization of independent auto-repair businesses negotiated supplier pricing and rebates for its members. It planned to use vendor rebates for administration, advertising, recruiting,…
Insurance-agent association denied business-league exemption
An association of insurance agents sought exemption as a business league under section 501(c)(6). Its members could sell products from several carriers, but membership was limited to agents who sold…
Real-estate education charity lost exemption over records and private benefit
The IRS revoked a real-estate education organization's section 501(c)(3) status after an examination of its finances and operations. Tuition revenue flowed through personal accounts, and the…
Medical charity lost exemption over insider benefits and poor records
A medical charity provided some free or reduced-cost care and accepted public and private insurance, but its founder controlled its operations and finances. The examination found numerous bank…
Member death-benefit association lost charitable exemption
An association accumulated funds to assist injured or disabled members and to pay funeral expenses when a member died. Its only reported activity was buying beverages for an annual inspection and…
Medical-interpreter certifier lost charitable exemption
An organization educated medical interpreters and operated a national certification program that administered written and oral exams. The IRS accepted that leadership training, workshops,…
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.