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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Farmers market primarily benefited vendors
A nonprofit operated a weekly farmers market and sought exemption under Section 501(c)(3). Its governing documents included agricultural and nutritional purposes broader than the listed exempt…
Energy research venture primarily served commercial interests
An organization sought Section 501(c)(3) exemption for energy research, prototype development, marketing, and licensing activities. Its founder and chief executive owned a patent-pending technology…
Farmers market did not qualify as a business league
An organization sought exemption as a business league under Section 501(c)(6). It operated a farmers market, charged vendors fees, and used some market revenue for improvements and promotion in the…
Exemption revoked after organization failed to provide records
The IRS repeatedly asked an exempt organization for documents concerning its receipts, expenditures, activities, governing purpose, financial statements, and minutes. The organization received at…
VEBA could offset member contributions against promissory notes
A voluntary employees' beneficiary association had required extra contributions from participating employers when first-year premiums were insufficient to meet a state minimum fund balance. Many of…
Foundation lost exemption for substantial insider benefits
A public charity that provided addiction counseling and transitional housing gave one executive control over its bank accounts and debit card. The examination found numerous unsubstantiated cash…
Housing applicant failed to establish charitable operation
An organization applied for Section 501(c)(3) status to operate accessible apartment housing for homeless and disabled veterans and civilians. The IRS asked for details about tenant eligibility,…
Revokes mutual water cooperative's tax exemption
A mutual water cooperative distributed water through a ditch system and had been exempt under section 501(c)(12). The IRS examination found that, in each of two years, less than 85 percent of the…
Denies chamber exemption because license bureaus were primary business
A local chamber of commerce reapplied for section 501(c)(6) exemption after a prior examination had revoked its status. The organization promoted local businesses and community development, but it…
Denies charity status to medical software support organization
An organization sought reinstatement of section 501(c)(3) status for its work supporting free, open-source electronic medical-record software. The software helped physicians operate medical…
Denies charity status to fee-based crowdfunding platform
An organization proposed to provide an online crowdfunding platform to high-profile individuals and organizations raising money for charitable causes. It would deduct a management fee and…
Denies exemption for vague youth aid and training programs
An organization applied for section 501(c)(3) status to support young people through savings assistance, activities, scholarships, mentoring, and job training. The IRS found that its articles did…
Trade association denied Section 501(c)(6) exemption because it primarily advertised members
An association of businesses along a scenic highway sought exemption as a business league under section 501(c)(6). Its members included galleries, lodging providers, restaurants, fishing lodges, and…
IRS denies business-league exemption to an umpires association that arranged member jobs
An association of baseball and softball umpires sought tax exemption as a business league under IRC Section 501(c)(6). It represented members before a state athletics body, negotiated and billed…
IRS denies social-welfare exemption to a small condominium association
A condominium association with fewer than 20 units applied for tax exemption as a social-welfare organization under IRC Section 501(c)(4). The association collected member dues to maintain a small…
IRS denies charitable exemption after applicant fails to document its organization and activities
An organization applied for recognition as a charity under IRC Section 501(c)(3), but it did not provide its articles of incorporation or attest that they contained the required purpose and…
IRS revokes charity whose only activity was a business networking event
A tax-exempt organization described its purpose as promoting trade, commerce, tourism, and friendship between countries. During the examined year, its only activity was a free trade, commerce, and…
IRS reclassifies fundraising charity as a private non-operating foundation
A private foundation raised money through solicitations, events, ticket sales, and merchandise. It distributed most of the proceeds to a public charity supporting cancer research and also funded a…
IRS revokes group-home charity that never began operations or answered examination requests
A charity was formed to operate a group home offering life-skills training to teenage girls. It reported no income and no operations for several years, did not file one required Form 990, and did…
IRS corrects scholarship group's public-charity classification to Section 509(a)(2)
A group of educators raised funds through a scholarship luncheon, a dance, and a regional conference, then awarded scholarships and book awards to students entering education. On its streamlined…
IRS revokes business league operated as a member referral and advertising network
A membership organization brought together one representative from each of many different businesses. Members met weekly to advertise their businesses, exchange referrals, give short commercials,…
IRS revokes charity that repeatedly refused to provide examination records
An organization recognized under section 501(c)(3) did not provide the records and information the IRS needed to examine its activities and operations. The IRS sent repeated letters, contacted board…
Hotel restoration project is denied Section 501(c)(3) status
An organization bought a vacant, deteriorated hotel near a historic business district and planned to renovate it into ten guest rooms, a dining room, and possibly a coffee shop, wine cellar, and…
Bionic-hand developer is denied exemption for private benefit and nonexempt purposes
An organization planned to develop open-source bionic hands and related control software for people with limb differences through worldwide collaboration, university programs, and hackathons. Its…
IRS revokes organization dissolved by court as fraudulent
An organization had been recognized under section 501(c)(3) to help convicted felons and their families pursue rehabilitation, housing, careers, counseling, and other goals. A state court later…
Homeowners' club loses exemption for enforcing covenants
A homeowners' social club operated a swimming pool, recreation area, and other facilities for members, their families, and guests. Its articles and bylaws also gave it authority to enforce the…
Dog-event club denied exemption for public business activity
An unincorporated purebred-dog club applied for section 501(c)(7) social-club exemption. It held recurring lure-coursing and conformation events open to members and the public, and event receipts…
Charity loses exemption for commercial catering operation
An organization had charitable, educational, religious, cultural, and relief purposes in its governing documents. An IRS examination found that its primary activity was operating a catering hall…
Inactive child-feeding charity loses exemption after fraud case
A charity participated in federal afterschool and summer feeding programs intended to provide meals to children in low-income areas. Its leader pleaded guilty to conspiring to obtain program funds…
Inactive charity loses exemption for no operations or records
An organization received section 501(c)(3) recognition but reported that it had conducted no activity from startup through a later ownership transfer. During a long examination, the IRS repeatedly…
Organization denied fraternal exemption because it lacks a lodge system
An organization formed to unite descendants of three families, help members, support immigrants, offer scholarships, conduct community activities, and earn rent from its building applied for…
Homeowners association denied social-welfare exemption because it primarily benefits its members
A homeowners association sought exemption as a social-welfare organization under section 501(c)(4). It maintained common areas and provided services such as landscaping, snow removal, exterior work,…
Religious organization loses exemption after commercial activity, private inurement, and inadequate records
A religious organization operated a retail book and gift shop, arranged pilgrimage tours, and received fees for tax-return preparation. The IRS found that these activities were conducted…
Organization loses exemption after ignoring audit requests and failing to substantiate its operations
An organization recognized under section 501(c)(3) was selected for examination of its activities and Form 990 reporting. The IRS sent several examination letters, including certified mail received…
Private foundation loses exemption for founder benefit, nonexempt activity, and inadequate records
A charitable trust was recognized as a private foundation based on plans to make grants to public charities. During examination, a founder said the foundation had never distributed any grants and…
Newly affiliated charity receives 30 days to revoke an old section 501(h) lobbying election
A health charity affiliated with another exempt health organization and changed its name after the affiliation. Within weeks, the organizations discovered that the charity had made a section 501(h)…
Gated homeowners association denied social-welfare exemption because its amenities serve members, not the public
A homeowners association maintained streets, gatehouses, landscaped grounds, pools, trails, courts, parks, and other amenities within a gated residential and office development. Residential owners…
Banquet-center business prevents charitable exemption
A membership organization sought recognition under section 501(c)(3) while operating a banquet center that it rented to the general public for weddings, business meetings, parties, and similar…
Bingo and political activities prevent social-welfare exemption
A political-party membership organization sought exemption under section 501(c)(4). Its main activity was weekly traditional and instant bingo, which consumed most of its staff and volunteer time…
Private foundation loses exemption after failing to substantiate charitable use of assets
A private nonoperating foundation told the IRS it would operate exclusively as a grantmaking organization. During examination, its returns reported no grants or contributions in the examined…
Missing organizing documents and finances prevent charitable exemption
An organization applied for section 501(c)(3) status using Form 1023-EZ and said it conducted youth camps and leadership conferences. During review, the IRS requested its filed organizing document,…
Missing purpose and dissolution clauses prevent charitable exemption
An organization applied for section 501(c)(3) status using Form 1023-EZ and supplied its articles of incorporation during review. The IRS found that the articles contained neither a clause limiting…
Community internet provider is denied social-welfare exemption
A nonprofit corporation sought exemption under section 501(c)(4) while operating a fiber-optic network through a disregarded LLC. It sold internet, Voice Over Internet Protocol telephone, and…
Arts contest is denied exemption for benefiting a related company
An organization planned to fund and promote creative people by running contests for artistic content. Contestants had to submit through a portal owned by a related for-profit company, which could…
Veterans organization loses exemption over public bingo operations
A veterans organization recognized under section 501(c)(19) operated a bingo hall and snack bar used by itself and multiple unrelated exempt organizations and open to the public. It maintained the…
Charity loses exemption after failing to produce audit records
An organization obtained section 501(c)(3) status after filing Form 1023-EZ and was later selected for an audit of a Form 990-N filing. The IRS sent multiple examination letters to the organization…
Closed college loses exemption after liquidation and nonresponse
A college entered bankruptcy, suspended classes, and sold all but one building under a court-approved liquidation plan. It no longer had a governing body, faculty, curriculum, enrolled students, or…
Farmers market loses exemption for commercial private benefit
A nonprofit operated a weekly farmers market where local farmers, food producers, artists, and other vendors sold goods to the public. Vendors paid annual membership dues and weekly stall fees, and…
Inactive service organization loses its exemption
An organization was formed to provide job-training facilities, residential treatment, and interpreter services for hearing-impaired people. During the examined year, it conducted no training,…
Inactive mentoring organization loses its exemption
A section 501(c)(3) organization focused on low-income and minority populations and provided mentoring to young people through workshops and other activities. It ceased operations because of…
Inactive disability-services organization loses its exemption
A section 501(c)(3) organization was formed to provide social services and education addressing the needs of people with mental or physical disabilities. It had provided residential treatment…
Business networking group denied tax exemption
A membership organization brought together business owners and professionals from many industries for monthly networking meetings, referrals, introductions, and business presentations. Members…
Recurring oil and gas royalties cost social club its exemption
A section 501(c)(7) social club operated recreational facilities for members and received revenue from dues, assessments, cabin rentals, and oil and gas rights. For several years, royalties and an…
Organization loses exemption after withholding examination records
An organization had previously lost its section 501(c)(3) exemption, unsuccessfully challenged that revocation in Tax Court, and later obtained a new exemption. During a later examination, an…
Inactive charity loses exemption after incomplete filings
A section 501(c)(3) organization had once collected clothing and goods for a shelter but later had no receipts, expenditures, or activities. Its president told the examining agent that maintaining…
Organization that never operated loses its exemption
A section 501(c)(3) organization did not respond to repeated letters and telephone messages seeking information for an examination. An officer eventually confirmed that the organization was…
Stalled housing charity loses its exemption
A section 501(c)(3) organization was examined to determine whether its activities matched its approved exempt status. Its sole officer said the organization had received a redacted amount of…
Organization loses exemption for nonexempt operation and inurement
The IRS revoked an organization's section 501(c)(3) exemption after concluding that it had not established operation exclusively for exempt purposes. The final letter also states that the…
Artist cooperative gallery denied charity status
A nonprofit gallery succeeded a for-profit gallery and provided member artists with display space, advertising, shopkeeping, marketing, and sales services. Working and consignment members set prices…
Foreign funding conduit and undocumented cash cause revocation
A domestic section 501(c)(3) organization solicited contributions in the United States to support the known activities of a foreign organization. It did not make proposal-based grants, document how…
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.