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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Hospital lost its exemption for failing the community health needs assessment rules
The IRS revoked a hospital organization's section 501(c)(3) status because it did not satisfy the community health needs assessment requirements of section 501(r). The hospital had obtained an…
Organization loses exemption after failing to provide audit records
The IRS revoked an organization's section 501(c)(3) exemption after it repeatedly failed to provide requested financial records and information about its activities. The organization did not respond…
Farmers market loses exemption for commercial private benefit
A nonprofit operated several farmers markets where farmers, food producers, artisans, and other vendors sold goods directly to the public. Vendors paid membership dues and market fees, while the…
Charitable trust may track a school's endowment without generating UBTI
A charitable remainder unitrust had a school as its trustee and sole charitable remainder beneficiary. The school proposed issuing contractual endowment units so the trust could receive returns…
School may issue endowment units to charitable trusts without UBTI
A tax-exempt school served as trustee and sole charitable remainder beneficiary of a charitable remainder unitrust. It proposed issuing contractual units tied to its pooled endowment so the trust…
Large bequest qualifies as an unusual grant
A publicly supported charity expected a large bequest from a donor who did not create or control the organization. The charity had consistently met the public-support test, actively solicited public…
Transitional-housing exemption denied for vague plans and private benefit
A nonprofit sought recognition under IRC § 501(c)(3) for a planned transitional-housing program. It repeatedly said that it would develop its facility, admissions policies, fees, services, staffing,…
Marine-services exemption denied for commercial operations
A nonprofit provided project planning and arranged underwater engineering and marine-science services for academic and research clients. It hired third-party contractors, charged clients its costs…
Fishing-market organization denied agricultural exemption
An organization formed to preserve a commercial fishing fleet bought seafood from local fishermen above open-market prices and resold it to the public, both uncooked and as prepared meals. The IRS…
College endowment units do not create UBTI for charitable remainder trust
A charitable remainder unitrust proposed exchanging assets for contractual units tied to the pooled endowment of the college serving as its trustee and remainder beneficiary. The units would provide…
Cost-only endowment management creates no UBTI for college
A tax-exempt college proposed issuing contractual units in its pooled endowment to a charitable remainder trust for which it was trustee and sole charitable remainder beneficiary. The trust would…
Purchasing and rebate services did not qualify as business-league activity
An organization claimed exemption as a section 501(c)(6) business league without having applied for recognition from the IRS. Its principal activities were negotiating bulk purchases and vendor…
Commercial pipe manufacturing did not qualify as charitable activity
A nonprofit successor to a for-profit business proposed developing machinery and manufacturing large corrugated metal pipes for bridges, overpasses, and disaster-recovery projects. It planned to…
Bingo operations and related-party rent defeated charitable exemption
A public charity regularly operated bingo and pull-tab games three days each week and used part of the proceeds for grants. The IRS found that gaming consumed nearly all of the organization's…
Regional chamber is denied section 501(c)(3) status
An organization already exempt under section 501(c)(6) applied to be recognized under section 501(c)(3). It promoted local businesses and tourism, published member business information, made…
Building-management company is denied section 501(c)(10) status
A limited liability company wholly owned by a section 501(c)(10) fraternal organization applied for its own exemption under that provision. The company maintained a building used by its owner and…
Exclusive referral network is denied business league exemption
A networking organization limited membership to one representative from each business or profession and required members to remain exclusive to the group. Members met weekly, tracked business…
Fraternal society lost exemption after failing to provide records
A fraternal beneficiary society had long been recognized as exempt under section 501(c)(8). During an examination, the IRS repeatedly requested records about the society's receipts, expenditures,…
Fee-based software and support services prevented charitable exemption
An organization sought section 501(c)(3) status to support independent community journalism through education, mentoring, administrative help, and an open-source publishing platform. It planned to…
Therapy-dog visits further charitable purposes
A section 501(c)(3) research institute proposed a free pet-therapy program for hospital patients, particularly children, and elderly nursing-home residents. Registered, health-certified therapy dogs…
Single-brand advertising group loses exemption
An organization of franchisees for one brand collected member fees and ran a common marketing and advertising program designed to increase awareness, customers, sales, and profits. The IRS concluded…
School support association denied exemption
An association raised money to buy supplies and equipment for a for-profit S corporation school owned by the association's president. The school was the association's only intended recipient,…
Recreational archery club denied section 501(c)(3) status
An archery club already exempt under section 501(c)(4) applied for section 501(c)(3) status. Its organizing document broadly authorized operating an archery club, and its dissolution clause did not…
Exemption revoked after audit noncooperation
The IRS audited a public charity and found that its articles lacked adequate exempt-purpose and dissolution clauses. The IRS repeatedly requested descriptions of the organization's activities,…
Donor-directed student-loan payments served private interests
An organization created a website through which borrowers could register their federal student loans and seek donations toward repayment. Sponsors could direct contributions to particular borrowers…
Open-source software organization is denied section 501(c)(3) status
An organization developed and promoted a particular free and open-source software project. It held conferences, maintained educational resources, supported volunteer development, and received most…
Burial-assistance association is denied fraternal exemption
An association collected membership fees and special contributions to help pay burial costs when a member died. It also planned membership meetings and classes on funeral planning and topics useful…
Automobile dealer advertising association loses business-league exemption
An association coordinated and funded advertising for a limited group of automobile dealers in a designated market area. Member contributions paid for television, radio, newspaper, digital, and…
Adult baseball league loses charitable exemption
A nonprofit operated an adult men's baseball league and charged team membership fees. Its activities centered on league play, game administration, statistics, prizes, playoffs, and an all-star game,…
Nonprofit loses exemption after failing to provide audit records
A section 501(c)(3) organization was selected for an audit of a Form 990-N filing. The IRS sent repeated letters to the organization and several officers, and it made multiple telephone calls, but…
Nonprofit loses exemption after ignoring record requests
A section 501(c)(3) organization was selected for an audit of a Form 990-N filing. The IRS mailed examination requests to the organization and several officers and repeatedly called its director and…
Inactive nonprofit loses charitable exemption
A nonprofit had previously been automatically revoked for failing to file annual returns and was later reinstated as a section 501(c)(3) organization. During a later examination, the IRS found that…
Electronic-waste facility loses tax-exempt status
An organization operated an electronic-waste disposal facility. The IRS found that it had not demonstrated that it operated exclusively for charitable, educational, or another exempt purpose. It…
Deer-herd loss plan denied agricultural exemption
A membership organization sought exemption as an agricultural organization under IRC § 501(c)(5). Its members would contribute money after covered deer-herd losses so the affected member could…
Apartment rentals to the public caused exemption revocation
The IRS revoked a nonprofit organization's exemption under IRC § 501(c)(3). During the examined years, the organization's only observed activity was renting its facility as apartments to members of…
Private foundation that stopped operating and never produced records loses exemption
A private foundation was selected for audit to confirm it was still doing the charitable work it had been approved for. Reaching it proved almost impossible. The examination report logs five…
Community organization loses exemption for social and recreational activities
A community organization said its mission was to improve quality of life through economic development, community and cultural activities, and educational advancement. Its activities included a…
Single-company insurance agents are denied business-league exemption
An association was formed for independent agents who sold insurance and financial products offered by one company. It planned education, training, networking events, and an annual awards banquet,…
Exemption revoked after the organization ignored the audit and let its corporate charter lapse
A small charity had filed only Form 990-N postcards, which carry no financial detail, so the IRS opened an examination to see whether it was still doing charitable work. The agent left voicemails,…
Back-health nonprofit is denied exemption for benefiting related insiders
A nonprofit proposed teaching a proprietary muscle-management program intended to reduce back pain. A related for-profit company owned by the nonprofit's president held the program's intellectual…
Record collectors' sales show does not qualify as a charity
A record collectors' club held monthly meetings and operated a large annual show where dealers rented tables and sold records, CDs, and memorabilia. Members received early access to the dealers, and…
Mismanaged charitable remainder trust faces income and excise taxes
A trust intended to qualify as a charitable remainder unitrust repeatedly included capital gains in trust income and paid more than its governing net-income limit permitted. The IRS concluded that…
Failed charitable remainder trust owes tax before beneficiary payout
A trust intended as a charitable remainder unitrust paid beneficiaries more than its net-income limitation allowed by improperly treating capital gains as income. The IRS concluded that the trust…
Captive insurer loses section 501(c)(15) exemption
A foreign captive insurance company claimed exemption as a small property and casualty insurer under section 501(c)(15). The IRS found that most direct-written contracts covered business or…
Captive insurer loses section 501(c)(15) exemption
A foreign captive insurance company claimed exemption as a small property and casualty insurer under section 501(c)(15). The IRS found that the company's direct-written contracts concentrated risk…
Branch-franchise applicant denied charity status over commercial and political concerns
A nonprofit applied for section 501(c)(3) status to conduct research and public education on environmental, social, and economic issues. Its website also promoted a fee-based franchise model for…
Captive insurer denied section 501(c)(15) exemption because most contracts were not insurance
A foreign captive insurer claimed exemption under section 501(c)(15) for four tax years after withdrawing an earlier exemption application. It issued property and casualty contracts to affiliated…
Civic education group denied charity status for partisan campaign activity
A volunteer civic group applied for exemption under section 501(c)(3), describing educational programs about government, public policy, and the Constitution. Its articles also allowed any lawful…
Charity status revoked over uncontrolled sponsorships and noncharitable activity
The IRS revoked a charity's section 501(c)(3) status after concluding that it could not show its cash disbursements were used exclusively for charitable purposes. The organization acted as fiscal…
Captive insurer denied exemption for insufficient insurance risk and distribution
A foreign captive company claimed exemption as a small property and casualty insurer under section 501(c)(15). The IRS found that only one of the direct-written contracts it reviewed covered an…
Historic church property transfer qualifies as an unusual grant
A cemetery association proposed transferring a historic church site and native prairie to a related public charity formed to preserve the property and provide educational programs. The property's…
Project-development corporation is denied 501(c)(3) status
A corporation applied for 501(c)(3) status to design and manage educational, scientific, technological, and business projects. The IRS repeatedly requested concrete details about its activities,…
Facility-rental organization loses 501(c)(3) status
An organization received 501(c)(3) status to promote economic and community development and support programs serving senior citizens and people with disabilities. An IRS examination found that the…
School health-benefit trust loses 501(c)(4) status but keeps section 115 exclusion
A trust formed by public school entities purchased and later self-insured health benefits for employees of participating school districts. The IRS concluded that the trust did not qualify under…
Religious publisher is denied 501(c)(3) status
A nonprofit corporation applied for 501(c)(3) status to publish and market religious books and resources. It charged authors subvention fees, paid royalties, sold books through commercial channels,…
Firearms organization loses 501(c)(3) status
A firearms-focused organization originally held section 501(c)(4) status and later received recognition under section 501(c)(3) after amending its stated purposes. During an examination, it reported…
Rental activity and a for-profit asset transfer cost exemption
A trust recognized under section 501(c)(3) and classified as publicly supported under section 509(a)(2) was examined after it incorporated and later terminated. Its support came primarily from…
Cultural center shops receive favorable foundation tax treatment
A private operating foundation planned a free community cultural center with museum exhibits, performance space, a library, an archive, a gift shop, and a coffee shop. The IRS found that the onsite…
Exemption revoked after nonresponse and corporate dissolution
A section 501(c)(3) organization did not provide records requested during an IRS examination and had not filed required Form 990-series returns for several years. Its state corporate status had also…
Exemption revoked after educational activities stopped
An exempt school lost its primary public-school funding and stopped serving students or conducting educational programs. It then rented parts of its property to food trucks, a day care center, and a…
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.