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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Social club loses exemption over nonmember income
A tax-exempt social club received more than the permitted share of its gross receipts from nonmembers through bar sales and green fees. The examination report said the club exceeded the 15 percent…
Vehicle-brand dealer group denied exemption
An association of vehicle dealers sought exemption as a business league under section 501(c)(6). Its membership was limited to dealers of one brand in a particular area, and its sole activity was…
Veterans post loses exemption over public bar and gambling operations
A veterans post held section 501(c)(4) status but operated a bar and gambling business that was open to the public six days a week. Although the post reported some community projects, the IRS found…
Hockey-referee group denied exemption for serving members' private interests
A membership organization supplied paid referees to youth hockey associations, collected the contract fees, assigned games to its referee members, and paid those members for their work. The group…
Education-fund group loses exemption for benefiting its workers
An organization arranged for members, usually parents of students, to staff concession stands at professional sporting events. It tracked each worker's hours, credited a corresponding amount to that…
Exemption revoked after organization withheld required records
The IRS repeatedly asked a section 501(c)(3) organization to provide records, financial statements, minutes, and documents needed to correct its articles' purpose clause. The organization received a…
Dog rescue loses exemption for commercial operation and private benefit
A self-declared section 501(c)(4) dog rescue charged fees to surrender and adopt selected breeds, did not accept strays, and stated no fee reductions based on income or need. It had never filed Form…
Exemption revoked after organization ignored audit document requests
A recognized section 501(c)(3) organization was selected for an audit of its Form 990-N filing. The IRS mailed two document requests, made repeated telephone calls, confirmed the organization's…
Exemption denied for an inadequate dissolution clause and unsupported individual assistance
An organization applied for section 501(c)(3) status using Form 1023-EZ and attested that its organizing document contained the required dissolution provision. The IRS found that the actual…
Exemption denied for commercial hall rentals benefiting a fraternal organization
A membership organization sought section 501(c)(3) status for maintaining a hall and grounds used primarily by a related section 501(c)(8) fraternal organization and rented to the public for events.…
Business league exemption denied for member-specific power contract negotiations
An organization of municipal and cooperative electric utilities sought section 501(c)(6) status after forming to negotiate a power purchase arrangement with a natural gas plant developer. Its only…
Exemption revoked after operations ceased and records were not provided
A section 501(c)(3) organization told the IRS that it had discontinued all activities and did not intend to operate again after its president relocated. During an examination, the IRS made repeated…
Exemption revoked for private benefits from individualized fundraising
A sports booster organization raised money for athletes who trained at a related for-profit gymnastics and cheerleading business. Members could reduce their own required assessments through…
Exemption revoked because a labor association served its members
A management-employee labor association had been recognized under section 501(c)(3), but its articles stated that it was organized for section 501(c)(5) purposes and directed assets on dissolution…
Exemption revoked for uncontrolled grants and unexplained officer spending
A public charity said it would make grants to institutions and individuals using board approval, reports on the use of funds, and records showing that recipients and purposes were charitable. During…
Social club exemption revoked for excessive nonmember income
A motorcycle club held competition events and provided campgrounds, grilling, showers, and other amenities for riders and their families. The events were open to nonmembers, advertised on the club's…
Exemption denied for substantial member-only benefit funds
An organization proposed public healthcare, rural development, cultural education, family assistance, farmer cooperatives, business training, advocacy, and other programs in the United States and…
Farmers' market denied section 501(c)(3) status for serving vendors' private interests
An organization sought reinstatement of section 501(c)(3) status after its earlier exemption was automatically revoked for failing to file Form 990 for three consecutive years. Its main activity was…
Exemption denied because applicant supplied no organizing document
An applicant for section 501(c)(3) status stated that it was not a corporation, limited liability company, unincorporated association, or trust. It did not submit an organizing document, bylaws, or…
Single-brand franchisee association denied business-league exemption
An association of current and former franchise owners sought exemption as a business league under section 501(c)(6). It conducted meetings, required-certification workshops, member updates, and…
For-profit egg-grader business denied agricultural-organization exemption
A for-profit corporation repaired commercial egg graders and sold refurbished graders and parts to egg producers. Its two directors were a married couple who also owned the stock, received monthly…
Exemption denied because incomplete application did not establish exempt operations
A nonprofit corporation applied for section 501(c)(3) status with broad community-assistance purposes and an unfiled set of articles referring to a church. Its application omitted a narrative of…
A homeowners' association was denied social club exemption
A homeowners' association applied for exemption as a social club under section 501(c)(7). Its main activity was maintaining residential property and setting aside funds for repairs and replacements,…
A resident-owned mobile home park corporation was denied exemption
A member-owned corporation sought section 501(c)(3) status so it could buy the land under a mobile home park and keep lot rents stable for resident homeowners. The residents would continue to own…
A hospital owner lost exemption after ceding control to a for-profit operator
A nonprofit hospital owner had been exempt under section 501(c)(3) since 1989 but later leased its hospital land, property, and equipment to a for-profit operator. The for-profit collected hospital…
Military fishing tournament did not qualify for section 501(c)(3)
A nonprofit corporation organized an annual three-day event for military service members that included a dinner, a military-installation tour, and a fishing tournament. The IRS found that the…
Pharmacy's commercial operations prevented section 501(c)(3) exemption
A nonprofit corporation planned to operate a pharmacy open to the general public. It would charge usual prices to insured and Medicare customers and pharmacy cost to poor, indigent, and underinsured…
For-profit governing documents defeat section 501(c)(3) exemption
The IRS denied section 501(c)(3) status to an organization that offered dance, cultural, educational, and youth programs. The organization was incorporated under a state's for-profit corporation…
Apartment rentals to the general public cause exemption revocation
The IRS revoked an organization's section 501(c)(3) exemption because its only observed activity during and after the examination years was renting its facility as apartment housing to members of…
Inactive organization loses exemption after failing to substantiate operations
The IRS revoked an organization's section 501(c)(3) exemption after the organization reported that it had conducted no activities or financial transactions since formation and had no bank account or…
Commercial school services cause exemption revocation
The IRS revoked an educational organization's section 501(c)(3) exemption after its operations shifted toward fee-based transportation, technology-network, and property-leasing services for school…
Trust owes UBIT on partnership and debt-financed income
An exempt trust reported unrelated business taxable income from partnership interests and debt-financed property, paid the resulting tax, and later claimed a refund. The IRS concluded that section…
Funeral-benefit membership group denied tax exemption
A membership organization collected membership fees and additional payments when a member died, then paid a fixed funeral benefit to the member's family. Its articles stated that its purpose was to…
Charity loses exemption over activities and fiscal sponsorships
The IRS revoked an organization's section 501(c)(3) status after concluding that its cash disbursements were not shown to be exclusively charitable. The organization conducted overseas aid and…
Rezoning agreement does not make foundation property debt-financed
A private foundation owned debt-free real property leased to unrelated businesses and hired an unrelated developer to pursue higher-density rezoning. The developer would initially bear most rezoning…
Exemption denied to fee-funded mortgage broker
A nonprofit applicant planned to originate mortgages for the general public and receive a one-percent loan origination fee from lenders for each loan it brokered. Its founder was also the owner of a…
Exemption revoked after organization ignored audit requests
A section 501(c)(3) organization was selected for examination but did not respond to repeated letters and telephone calls seeking records needed to audit its Form 990. Some certified letters were…
Exemption denied for defective organizing terms and inadequate records
An organization applied to regain section 501(c)(3) status after an automatic revocation for failing to file required annual returns. Its articles directed assets on dissolution to a named…
Export-promotion organization failed both section 501(c)(3) tests
An organization was formed to support a section 501(c)(6) group and a government office in promoting U.S. exports, initially through a sponsored conference. It planned to collect registration and…
Exemption revoked after the organization ignored audit requests
A section 501(c)(3) organization was selected for an examination of its Form 990-N but did not provide the information needed for the audit. The IRS sent repeated letters to the organization, a…
Real estate association denied section 501(c)(6) exemption because its MLS served members
A real estate association applied for exemption as a business league under section 501(c)(6). Its activities included advocacy, education, member meetings, community events, public information, and…
Condominium association denied section 501(c)(4) exemption because it served unit owners
A ten-unit condominium association applied for exemption as a social welfare organization under section 501(c)(4). It maintained the common areas and building exterior, and each unit owner held an…
Administrators association denied section 501(c)(4) exemption because it primarily served members
An association of certified educational administrators applied for exemption under section 501(c)(4). It represented members and fee-paying nonmembers in collective bargaining over contracts and…
Fire department assistance fund denied section 501(c)(3) exemption because it primarily benefited members
A fund associated with a fire department applied for exemption as a charitable organization under section 501(c)(3). Its governing documents focused on helping members and their immediate families…
Car shows serve a substantial recreational purpose
The IRS denied section 501(c)(3) status to a car club whose primary activity was hosting shows for members, car enthusiasts, and the public. The club planned seminars and said some proceeds would…
Dental organization loses exemption for commercial operation and inurement
The IRS revoked a dental organization's section 501(c)(3) status after concluding that it operated like a commercial dental practice and allowed its earnings and assets to benefit private…
Timeshare charity loses exemption for private benefit and commercial activity
The IRS revoked the exemption of an organization that solicited timeshare donations, sold the properties, and distributed some net proceeds to charities chosen by donors. Its sole voting member also…
Unexpected scholarship gift qualifies as an unusual grant
A publicly supported charity that provided professional scholarships expected to receive a cash gift far larger than its annual budget and normal grants. The donor had not created or controlled the…
Private-road homeowners association denied exemption
A homeowners association with four member properties applied for section 501(c)(3) status. One related business owned two of the four homes, and related individuals controlled the association's…
Referral networking group denied business-league exemption
A business networking group allowed only one representative from each industry or professional classification. Its weekly meetings included member sales pitches, referrals, testimonials, and…
Innovation consulting organization denied exemption
An organization proposed to help commercialize life-science and emerging-technology innovations through innovation hubs, research evaluation, healthcare-access models, and industry-academic data…
Public trap-shooting events defeated social-club exemption
An unincorporated trap-shooting club sought exemption as a social club under section 501(c)(7). Most of its events were open to anyone who paid the fee and followed the rules, and nonmember receipts…
Charity lost exemption after failing to provide audit records
The IRS repeatedly asked a section 501(c)(3) organization for records needed to examine its receipts, expenditures, activities, and Form 990. Although the organization's president spoke with the…
Charity lost exemption after ignoring audit requests
A section 501(c)(3) organization did not provide the financial and activity information requested during an examination of its Form 990-N. The IRS mailed several requests and made repeated telephone…
Foreign stock purchases and private benefits caused revocation
A section 501(c)(3) organization sent substantial charitable funds to accounts abroad for the purchase of shares in a publicly traded company. The examination report states that the treasurer knew…
Artists' sales show primarily benefited members
An organization served as an umbrella for local artists and promoted one annual open-studio sales show. It had obtained exemption partly in hopes of securing grants, but no grant opportunity was…
Restaurant business overwhelmed claimed exempt activities
A section 501(c)(3) organization described youth mentoring, workshops, school-supply distributions, and restaurant-based workforce training as its exempt programs. It did not provide evidence that…
Industrial park association was denied social-welfare exemption
An association of industrial park lot owners applied for exemption as a social-welfare organization under section 501(c)(4). It maintained the park's common areas, paid utilities and other operating…
Military morale club was denied charitable exemption
An unincorporated association limited membership to military personnel at a particular location who held a specified rank. It organized picnics, paintball trips, gaming and sports tournaments, and…
Single-vendor software group was denied business-league exemption
A software user group sought exemption as a business league under section 501(c)(6). Membership was limited to organizations licensed to use a particular commercial software system, and most forum…
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.