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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PLR 201318031: Rollover deadline waived after a financial institution mishandled instructions
An employee took a distribution from a former employer's 401(k) plan and instructed the plan administrator to roll most of the account into an IRA. The financial institution instead transferred only…
PLR 201318030: Three retirement plans qualify as church plans
The IRS considered whether a nonprofit hospital's defined benefit, money purchase, and tax-deferred annuity plans qualified as church plans under IRC § 414(e). The hospital was controlled by a…
PLR 201318029: Rollover deadline waived after a custodian opened the wrong account
An IRA owner intended to move retirement funds into a savings account within his IRA after a certificate of deposit matured. The custodian instead opened a non-IRA savings account, creating an…
IRS proposed revocation for failure to file required returns
The IRS proposed revoking a social welfare organization's tax-exempt status because it failed to file required Form 990 returns and did not provide the requested records or responses. The…
Other 201318027: IRS revokes a dog club's tax-exempt status
The IRS revoked a dog club's exemption under section 501(c)(3). The organization conducted dog shows, obedience training, and related matches, and it argued that these activities educated dog owners…
Other 201318026: IRS revokes a social club's tax-exempt status
The IRS revoked a social club's exemption under section 501(c)(7). The club promoted clay target shooting, conducted shooting events, and admitted special or daily members who were treated as…
Other 201318025: IRS revokes an organization's tax exemption for filing failures
The IRS proposed revoking an organization's exemption under section 501(c)(4) because it did not respond to IRS correspondence or file required Forms 990 for the relevant tax periods. The…
Other 201318024: IRS proposes revoking a neighborhood organization's exemption
The IRS proposed revoking a neighborhood organization's exemption under section 501(c)(4). The organization provided newsletters, directories, community events, and a security patrol for…
Other 201318023: IRS revokes a private residential association's exemption
The IRS revoked a residential association's exemption under section 501(c)(4). The association maintained private roads and common areas, provided security patrols, and served a restricted…
Other 201318022: IRS revokes a private homeowners association's exemption
The IRS revoked a homeowners association's exemption under section 501(c)(4). The association maintained private common areas, including a swimming pool, play areas, roads, and other facilities, and…
Other 201318021: IRS revokes a members-only organization's exemption
The IRS revoked a members-only organization's exemption under section 501(c)(4). The organization operated a bar and function hall, provided member benefits, and donated some income to local schools…
Other 201318020: IRS revokes a neighborhood patrol association's exemption
The IRS revoked a neighborhood patrol association's exemption under section 501(c)(4). The association hired off-duty police officers to patrol a residential subdivision, provided emergency contact…
Other 201318019: IRS revokes a dormant group's exemption for filing failures
The IRS revoked a subordinate organization's exemption under section 501(c)(4). The organization had ceased operations, had no financial resources or assets, and failed to file required returns and…
Other 201318018: IRS revokes an inactive organization's exemption
The IRS revoked an organization's exemption under section 501(c)(4) because it had stopped operating. During the examination, a representative said that the organization no longer conducted…
Other 201318017: IRS proposes revoking an agricultural and equestrian facility's exemption
The IRS proposed revoking an organization's exemption under section 501(c)(3). The organization planned to own and operate facilities for agricultural, equestrian, and other public events, but later…
Other 201318016: IRS revokes a homeowners association's section 501(c)(4) exemption
The IRS revoked a homeowners association's exemption under section 501(c)(4). The association restricted access to its common areas to members and guests, and used police assistance, gates, keys,…
Other 201318015: IRS proposes revoking a volunteer fire organization’s exemption
The IRS proposed revoking an organization’s exemption under section 501(c)(4). The organization was formed to provide volunteer fire and emergency services, but the IRS found almost no documented…
Other 201318014: IRS revokes a credit-counseling organization’s exemption
The IRS revoked a credit-counseling organization’s exemption under section 501(c)(4), effective January 1, 20XX. The organization initially proposed debt-management and counseling services for needy…
Other 201318013: IRS revokes a private golf and country club’s exemption
The IRS revoked a private golf and country club’s exemption under section 501(c)(4), retroactive to January 1, 20XX. The organization operated a public golf course alongside member facilities, but…
Other 201318012: IRS revokes a homeowners association’s section 501(c)(3) exemption
The IRS revoked a homeowners association’s exemption under section 501(c)(3), effective January 1, 20XX. The organization had originally been treated as a municipal corporation, but after the…
Other 201318011: IRS revokes exemption for failure to file returns and maintain records
The IRS revoked an organization’s exemption under section 501(c)(4), effective January 1, 20XX. The organization failed to respond to IRS correspondence, file required Form 990 returns, and maintain…
Other 201318010: IRS revokes section 501(c)(4) status but finds section 501(c)(7) qualification
The IRS revoked the organization’s exemption under section 501(c)(4), effective January 1, 20XX. The organization hosted social events for residents of a residential tower complex, but did not…
Other 201318009: IRS revokes an organization’s tax-exempt status
The IRS revoked the organization’s exemption from federal income tax under section 501(c)(3), effective January 1, 20XX. The letter says the organization operated for a substantial non-exempt…
PLR 201318008: IRS approves educational grants supporting international scholarship on American art
The IRS approved a private foundation’s procedures for awarding educational grants under section 4945(g)(3). The program will support scholarly publications about American art, including…
PLR 201318007: IRS grants extra time to file Form 3115 for an accounting-method change
The IRS granted a taxpayer a 60-day extension to file an original Form 3115 with an amended consolidated return. The form was needed to request an accounting-method change for repair and maintenance…
PLR 201318006: IRS declines to disallow or recapture investment tax credit after rate-template error
The IRS ruled that a regulated public utility did not have to disallow or recapture its investment tax credit after an error in the formula templates used to set transmission rates. The templates…
PLR 201318005: IRS declines to disallow or recapture investment tax credit after rate-template error
The IRS ruled that a regulated public utility did not have to disallow or recapture its investment tax credit after an error in the formula templates used to set transmission rates. The templates…
PLR 201318004: IRS declines to disallow or recapture investment tax credit after utility rate-template errors
The IRS ruled that a regulated public utility did not have to disallow or recapture investment tax credits after errors in the formula templates used to set wholesale electric and transmission…
PLR 201318003: Charitable gift of section 1250 property is not reduced by the corporate depreciation adjustment
The IRS ruled that a corporation’s charitable deduction for contributing certain section 1250 property to section 501(c)(3) organizations would not be reduced by 20 percent of the property’s…
PLR 201318002: IRS grants extra time to file Form 3115 after taxpayer relied on a tax professional
The IRS granted a taxpayer a 60-day extension to file the original Form 3115 needed to change its accounting method. The taxpayer had filed the form but failed to attach a copy to its consolidated…
PLR 201318001: Benefits from a public-employee death plan are excluded from income
A political subdivision asked about a plan that pays one-time benefits to qualifying beneficiaries of certain public employees who die or suffer a fatal injury in the line of duty. The IRS concluded…
PLR 201317026: Multiemployer plan receives five-year funding amortization extension
A multiemployer plan requested a five-year automatic extension for amortizing specified unfunded liabilities. The IRS approved the request under section 431(d)(1) after the plan submitted the…
PLR 201317025: Government employer may pick up mandatory retirement contributions
A municipality asked whether it could pick up mandatory employee contributions to a defined benefit governmental plan under section 414(h). The IRS concluded that the contributions qualify whether…
PLR 201317024: IRS waives the 60-day IRA rollover deadline
An individual received a distribution from an individual retirement annuity but missed the 60-day rollover deadline after relying on misleading information and errors by an insurance representative.…
PLR 201317023: IRS waives rollover deadline after mistaken tax withholding
A surviving spouse intended to transfer inherited IRA funds directly from one IRA to another. The financial institution mistakenly withheld an amount for federal income taxes even though the…
PLR 201317022: IRS waives rollover deadline after IRA funds were misdirected
An individual asked to change investments within an IRA, but a financial institution transferred the funds out of the IRA into a non-qualified account instead. The individual did not request a…
PLR 201317021: IRS declines to waive rollover deadline after medical-expense withdrawal
An individual withdrew money from an individual retirement annuity to pay medical expenses and insurance premiums during the individual's spouse's serious illness. The taxpayer later learned about…
IRS 201317020: Exempt status revoked after organization failed to provide records
The IRS issued a final adverse determination revoking an organization's section 501(c)(3) exemption effective January 1 of the redacted year. The IRS stated that the organization had not established…
PLR 201317019: IRS approves mentorship grants for disadvantaged young adults
The IRS approved a private foundation's procedures for awarding educational grants under IRC section 4945(g)(3). The program will support young adults ages 18 to 30 who have faced significant…
PLR 201317018: IRS rules that an estate settlement does not create self-dealing
The IRS ruled that an estate settlement involving a private foundation would not create direct or indirect self-dealing under IRC section 4941. The estate's surviving children agreed to purchase…
PLR 201317017: IRS distinguishes reporting rules for IRA and 529 account bonuses
The IRS ruled on the information-reporting treatment of bonuses a financial-services group planned to pay when clients opened and funded IRA or section 529 accounts. Bonuses credited to an IRA were…
IRS revokes a social club's section 501(c)(7) exemption
The IRS revoked a social club's exemption under IRC section 501(c)(7). The club operated shooting ranges, a fishing pond, a clubhouse, and related recreational facilities, and opened many of those…
IRS revokes a dog club's section 501(c)(7) exemption
The IRS revoked a dog club's exemption under IRC section 501(c)(7). The organization held dog shows, obedience trials, sanctioned matches, and other activities in which the general public regularly…
IRS revokes a campground social club's section 501(c)(7) exemption
The IRS proposed revoking a campground social club's exemption under IRC section 501(c)(7). The organization had sold its assets to pay liabilities, distributed the remaining funds to members, and…
PLR 201317013: IRS finds preferential cleanup payments jeopardize section 501(c)(4) status
The IRS ruled against a section 501(c)(4) environmental cleanup organization that proposed reducing a member's cleanup-related liability through a special fund and reimbursement agreement. The…
IRS denies section 501(c)(3) recognition after applicant fails to substantiate operations
The IRS denied an organization's application for recognition under IRC section 501(c)(3). The applicant described drug-rehabilitation, counseling, religious, and outreach activities, but did not…
IRS denies section 501(c)(3) recognition to a fee-based charity investment fund
The IRS finalized its denial of section 501(c)(3) recognition for a foreign common investment fund serving registered charities. The fund’s governing declaration did not expressly limit its purposes…
TAM finds trusts did not materially participate in an S corporation's activities
The IRS considered whether two complex trusts materially participated in the relevant activities of an S corporation for the alternative minimum tax rules. A beneficiary served as the corporation's…
CCA concludes exchangeable debentures were not qualified covered call options
Chief Counsel Advice considered whether exchangeable debentures and their embedded exchange features qualified for the covered-call exception to the straddle rules. The IRS concluded that the…
PLR 201317008: IRS grants extra time to make section 338(g) elections
The IRS granted a purchaser 45 days to make section 338(g) elections for the acquisition of one target and the deemed acquisitions of two subsidiaries. The elections had been missed because the…
PLR 201317007: Disability benefits qualify for exclusion as compensation for injuries or sickness
The IRS ruled that certain disability benefits paid to police officers and firefighters, or continuation benefits paid to survivors, would not be included in gross income. The ruling applied to…
PLR 201317006: IRS grants extra time to file a LIFO election
The IRS granted a taxpayer 30 additional days to file Form 970, the form used to elect the LIFO inventory method. The taxpayer had received inventory during an internal restructuring but had not…
PLR 201317005: Subsidiary treated as joining a consolidated return
The IRS treated a largely dormant subsidiary as if it had filed the required Form 1122 and joined its parent's initial consolidated federal income tax return. The subsidiary had been omitted from…
PLR 201317004: IRS treats an S corporation election as continuing after an inadvertent termination
The IRS ruled that an S corporation's election terminated when shares were transferred to a trust that had not made the required Electing Small Business Trust election. The IRS found that the…
PLR 201317003: Termination payment must be capitalized and may be recovered under section 167
The IRS considered the tax treatment of a payment made to terminate two franchise agreements. It ruled that the payment had to be capitalized as a newly created intangible under the regulations for…
PLR 201317002: IRS grants extra time to elect the section 831(b) alternative tax
The IRS granted an insurance company 60 days to make a section 831(b) election for a specified tax year. The company had missed the deadline after its accounting firm failed to request an extension…
PLR 201317001: IRS approves REIT treatment for correctional and community facilities
The IRS ruled that correctional, detention, halfway-house, and youth-services facilities were not health care facilities for the REIT rules, even though some provided limited medical or…
PLR 201316028: IRS declines to waive the 60-day IRA rollover deadline
An individual received a distribution from an IRA and transferred it to a non-IRA account during divorce proceedings. She did not realize until the following year that the amount should have been…
PLR 201316027: IRS waives the 60-day IRA rollover deadline after a bank error
An individual requested a distribution from an IRA intending to roll it into another IRA. A bank representative instead prepared paperwork for a non-IRA certificate of deposit, and the individual…
PLR 201316026: IRS declines to waive rollover deadlines for two taxpayers
Two taxpayers transferred distributions from their separate IRAs to non-IRA accounts at the same company to increase their trading power for stock options. They later argued that they did not…
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.