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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Denies exemption for high school class reunions
An unincorporated association applied for section 501(c)(3) status to organize periodic high school class reunions for classmates and their families. It planned annual or twice-yearly fundraisers to…
Revokes inactive aromatherapy foundation's exemption
A foundation was recognized under section 501(c)(3) to provide aromatherapy education, public seminars, professional training, and research support. After a county changed its transient-occupancy…
Preserves VEBA exemption and avoids UBTI for health benefit subaccount
A voluntary employees' beneficiary association funded retiree health benefits for collectively bargained employees. It proposed transferring assets once to a new internal subaccount that would pay…
Denies exemption to market-rate veterinary practice
A professional service limited liability company applied for section 501(c)(3) status to provide veterinary services and eventually find homes for abandoned animals. Its sole member shared in…
Denies business league exemption to farmers' market
A farmers' market sought exemption as a business league under section 501(c)(6). It provided member vendors with physical and online selling venues, advertising, electrical access, and other market…
Denies social welfare exemption to commercial property association
An association of commercial property owners sought exemption as a social welfare organization under section 501(c)(4). It planned to maintain privately owned common areas, parking, landscaping,…
Denies social welfare exemption to condominium association
A condominium owners' association sought exemption as a social welfare organization under section 501(c)(4). It collected assessments to maintain the complex's exterior structures, grounds, pool,…
Denies exemption to member-focused internet exchange
An organization sought section 501(c)(3) status to establish and operate a neutral regional internet exchange. Members would pay port fees, receive below-market access, and exchange local internet…
Denies social welfare exemption to member-owned well and dock association
A homeowners' association collected mandatory annual fees to pay expenses for a well and boat dock owned in common by its member households. It did not own the facilities, restricted their use and…
Denies exemption to organization serving one family lineage
An organization formed to improve the educational and economic prospects of the descendants of two individuals and their siblings applied for exemption under section 501(c)(3). It planned…
A members-only funeral benefit society is denied 501(c)(3) status
A mutual-aid society applied for tax-exempt charitable status using the streamlined Form 1023-EZ, and the IRS denied it under § 501(c)(3) after a technical review. The group works like a…
A "church" organized as a for-profit LLC with a paid recruiting scheme is denied 501(c)(3) status
An organization applied for recognition as a tax-exempt religious charity but the IRS denied it under § 501(c)(3). Two problems doomed the application. First, it failed the organizational test: the…
An animal sanctuary run out of the founders' home is denied 501(c)(3) status for inurement
A husband and wife formed a nonprofit to run a permanent sanctuary for previously ill, abused, or neglected animals, which lived in the couple's own home. The IRS denied the organization recognition…
A charity formed to aid one boat crew's families is denied 501(c)(3) status
An organization was formed to collect donations and hand them out to the families of the deceased crew of a fishing vessel, a group of fewer than ten identified individuals. Its own directors and…
Scholarship procedures for underprivileged students approved
A private foundation proposed scholarships to help underprivileged students complete undergraduate or graduate degrees. Applicants would provide academic records and essays, and a selection…
Horse futurity organization denied Section 501(c)(3) status
An organization applied for Section 501(c)(3) status to operate an all-breed horse futurity with competitions, an online stallion-service auction, and a payback program for owners. Its website…
Exemption revoked for a donor-controlled partnership gifting program
A charity accepted donated nonvoting interests in partnerships and limited liability companies through arrangements created and administered by a professional adviser. The IRS examination found that…
Property-holding charity reclassified as a supporting organization
A property-holding charity received almost all of its support from rents and did not meet the public-support tests for classification under Section 509(a)(1) or 509(a)(2). Its sole supported…
Inactive organization's Section 501(c)(3) status revoked
An educational organization had reported little activity for several years and failed to file one annual return. A later pledge agreement called for a large contribution that the organization would…
Exempt status revoked after organization failed to provide audit records
The IRS selected a charitable organization for an audit of its annual return and repeatedly requested financial records, minutes, and other information. An officer said the records were stored on a…
Social club exemption revoked for excess nonmember income
A social club promoted horses and horsemanship through shows, play days, trail rides, meetings, and use of its hall and arena. Some activities and facilities were available to nonmembers and the…
Breast cancer charity revoked for private benefits and inaccurate filings
A charity said its mission was to assist breast cancer patients and support education and research. The IRS found that its exempt activity was secondary to professional fundraising fees, insider…
IRS revokes a social welfare organization's tax exemption
An organization had been recognized as tax-exempt under Section 501(c)(4) and reported activities for emergency service workers, including social events, an awards banquet, a scholarship, and…
Charity exemption revoked after repeated examination contacts failed
A charity obtained Section 501(c)(3) status through Form 1023-EZ and was later selected for examination. IRS letters sent to several located addresses came back undeliverable or refused, calls to…
Inactive research organization agreed to revocation
An organization conducted research and education on adult psychological development through a website, programs, and memberships. After moving to another state, it could not obtain recognition there…
Bingo organization loses exemption for private benefit and minimal charity
An organization recognized under Section 501(c)(3) held volunteer-run bingo games every Friday and reported no other activity. It made only three charitable contributions during the examined year…
Golf club loses social-club exemption for public business activity
A golf club recognized under Section 501(c)(7) operated seasonally and regularly opened its course, carts, food, and bar services to the public. It advertised public weekday access, online tee…
Inactive community organization loses Section 501(c)(3) status
An organization had been recognized under Section 501(c)(3) to provide language instruction, translation, help with government forms and job searches, youth support, and assistance to a Muslim…
Unfunded organization loses exemption after incomplete dissolution
A recently recognized charity intended to distribute religious teddy bears to children but was unable to obtain funding. Its president said the organization wanted to close, filed a Form 990-N…
IRS revokes exemption after organization ignores audit requests
An organization recognized under Section 501(c)(3) was selected for an audit of its Form 990. The IRS repeatedly sent examination letters and information requests and made numerous telephone calls,…
Government hospital loses Section 501(c)(3) status for Section 501(r) failures
A government-owned hospital also held a separate Section 501(c)(3) determination, making it a dual-status hospital subject to Section 501(r). The IRS found that the hospital had not adopted an…
Exemption revoked after organization failed to provide records
An organization recognized under Section 501(c)(3) did not maintain an available business office or representatives and repeatedly failed to arrange an examination or provide requested…
Tourism promoter loses exemption for commercial activities
A destination-marketing organization promoted tourism and local businesses through advertising, trade shows, referrals, visitor guides, and member benefits. Its income came substantially from…
Inactive youth-health charity loses exemption
An organization formed to promote health, exercise, and healthy eating among school-age children reported no funding and did not substantiate that it conducted field days, fitness classes, or…
Scholarship trust loses exemption for trustee withdrawals
A private-foundation trust made college scholarships but its sole trustee also regularly withdrew substantial trust funds for personal purposes. The trustee recorded the withdrawals as a note…
Limited partnership loses exemption after failing examination requests
An organization obtained Section 501(c)(3) status through Form 1023-EZ, but state records identified it as a limited partnership rather than a corporation, association, or trust. During an…
Defunct nonprofit loses exemption after failing to provide records
A nonprofit corporation stopped operating and failed to file its required Form 990-N return. Its president told the IRS that the organization had folded, had no assets to distribute, and would…
Social club loses exemption for recurring nonmember income
A Section 501(c)(7) social club earned rental income from two apartments above its clubhouse. Its Forms 990 showed recurring nonmember income above the statutory limits: no more than 35 percent of…
Jazz organization loses exemption for restaurant-focused activities
An organization formed to advance jazz education moved its performances to a restaurant controlled by substantially the same management. The IRS found that most of its activities consisted of…
Cultural organization loses exemption after withholding audit records
A public charity formed to present theater, promote the arts, and revitalize a historic venue did not provide records needed to evaluate its spending, contracts, loans, and possible private benefit…
Cemetery loses mistaken Section 501(c)(3) exemption
A cemetery organization had previously been exempt under Section 501(c)(13), but after automatic revocation it reapplied on Form 1023-EZ and obtained Section 501(c)(3) status instead of using Form…
Disability-services charity loses exemption for deficient articles and noncooperation
An organization offered therapy, counseling, and educational services to children with disabilities, but its articles of incorporation lacked the required dissolution clause. During an examination,…
Law-enforcement association denied VEBA exemption
A membership organization for active and retired law-enforcement officers applied for exemption as a voluntary employees' beneficiary association under Section 501(c)(9). It collected dues and…
Political association denied charitable exemption
An unincorporated association sought recognition as a Section 501(c)(3) charity. Its bylaws promoted political activity, required officers and members to be voters of one political party, and…
Equine clinic loses exemption for commercial activity and private benefit
A tax-exempt organization said it would prevent cruelty to horses, conduct research and education, provide disaster relief, make charitable grants, and offer veterinary services at below-market…
Youth sports charity is reclassified under Section 509(a)(2)
A Section 501(c)(3) youth sports organization operated two gymnasiums and received most of its support from basketball and volleyball programs, camps, tournaments, concessions, and hotel…
Charity loses exemption after failing to substantiate its activities and spending
A charity proposed a broad range of community programs and later operated thrift stores that it said benefited military veterans. By the examination period, it had no current activities and had not…
Member-focused charity loses exemption for private benefit
A charity connected with a multi-state membership organization raised money through events and owned land used for gatherings. It also made loans and funeral-expense payments to members and their…
Gaming and insider benefits caused revocation of a youth performance organization's exemption
The IRS revoked the Section 501(c)(3) status of an organization formed to support drum and bugle corps music and later operating color guard programs. The examination found that bingo, other gaming,…
Foundation conversion allowed beneficiary payments and split-year reporting
A non-functionally integrated Type III supporting organization planned to become a private foundation and combine two asset funds after a court-approved trust modification. Under a settlement,…
Farmers' market denied Section 501(c)(5) status
A nonprofit operated a year-round farmers' market where member vendors paid membership and stall fees to sell locally produced food, crafts, and other goods. The organization argued that its members…
Marina social club lost exemption over leasing and nonmember income
A marina organization had been recognized as a Section 501(c)(7) boating social club. Members owned boat slips, and the organization actively arranged rentals of unused slips and storage space to…
Online gaming community denied Section 501(c)(3) status
An organization operated online game servers, moderated chat, contests, radio shows, and occasional in-person meetups intended to connect LGBTQ people and allies in a supportive environment. Its…
Organization denied exemption after incomplete application
An organization applied for Section 501(c)(3) status and described fundraising at professional sporting events, services for children seeking their first jobs, and benefits for families affected by…
Taxi-driver member benefit plan denied exemption
An organization for taxi drivers offered networking, road-test guidance, driving-application help, and free finance courses. It also operated a paid social plan described as life insurance for…
Cattle breeders' show chapter did not serve a charitable public purpose
A local chapter of cattle breeders sought recognition as a Section 501(c)(3) charity. It was formed so a small group of members could participate in an annual national show and exhibit their own…
Hunting and fishing organization denied Section 501(c)(3) status
A hunting and fishing organization promoted sportsmanship and supported programs for young people, disabled people, and women. Its activities included hunter safety, trapper education, archery and…
Software user association denied business-league exemption
An association brought together customers, vendors, consultants, and former officers connected with three software products owned by one corporation. It operated a member forum, website, file…
Denies social welfare exemption to tennis umpire association
A tennis umpire association sought reinstatement of tax-exempt status as a social welfare organization under section 501(c)(4). Its main activity was referring member umpires to sanctioned tennis…
Hockey officiating scheduler primarily served individual members
An association sought recognition as a tax-exempt business league under Section 501(c)(6). It scheduled trained hockey officials for member rinks, billed the rinks, collected the fees, and…
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.