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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Exemption revoked after residential care activities ended
A section 501(c)(3) organization had provided housing and support services for people living with AIDS through public health contracts. After losing those contracts, it stopped providing those…
Public golf course does not qualify as an exempt social club
A nonprofit golf course sought exemption as a social club under section 501(c)(7). The course and clubhouse were regularly open to the public, nonmembers generated more than 25 percent of receipts,…
Professional rodeo association does not qualify under section 501(c)(3)
A membership association conducted about fourteen rodeos each year, charged participants entry fees, charged spectators admission, and awarded cash prizes. Its bylaws emphasized promoting…
Dealer advertising cooperative loses section 501(c)(6) exemption
A self-declared association of automobile dealerships pooled dealer contributions to fund advertising for vehicles from one manufacturer in a defined television market. The IRS concluded that the…
Transportation LLC is denied charity status for private benefit and commercial operations
An LLC sought section 501(c)(3) status to provide scheduled transportation to people with disabilities and other clients affected by local budget cuts. It shared vehicles, drivers, an address, and…
Housing general partner is denied exemption for benefiting for-profit owners
An organization served as the one-percent general partner of a limited partnership that owned a 32-unit apartment building. The remaining partnership interests were held by a for-profit LLC and two…
Large grant from unrelated foundation qualifies as an unusual grant
A publicly supported charity serving at-risk youth and foster children sought a large grant from a newly formed private foundation to expand programs addressing teen homelessness. The grant was…
Health-plan organization denied exemption under both 501(c)(3) and 501(c)(9)
An organization applied for exemption twice at once, as a charity under section 501(c)(3) and as a voluntary employees' beneficiary association (VEBA) under section 501(c)(9). Its stated purpose was…
Condominium business park does not qualify as an employee-benefit association
A condominium business park sought exemption as a voluntary employees' beneficiary association under section 501(c)(9). Its members joined by purchasing condominium units, and membership was not…
Community hospital lease furthers charity and avoids debt-financed property treatment
A nonprofit association had long operated a small community hospital but faced declining reimbursements, limited capital, and insufficient scale. A state-commissioned study recommended affiliation…
Captive insurer denied section 501(c)(15) exemption
A foreign captive company claimed exemption as a small insurance company under section 501(c)(15). It issued fourteen direct-written contracts covering affiliated businesses and participated in…
Weekly market operator loses business-league exemption
An organization recognized under section 501(c)(6) operated a weekly open-air downtown market where members sold locally grown products, prepared food, and handicrafts. Members paid for selling…
Art gallery does not qualify as a social club
An organization formed to promote artists applied for exemption as a social club under section 501(c)(7). Its members and consignment artists displayed artwork for sale in a leased gallery, paid…
Online clothing seller fails the charitable operational test
An organization planned to design and sell clothing online, donate a similar item for each item sold, and give any remaining money to people in need or to charitable organizations. Its compensated…
Restaurant operations defeat charitable exemption
An organization proposed domestic-violence education, survivor assistance, youth programs, and other charitable activities, but expected two public restaurants to provide most of its revenue. The…
Provider-promotion activities cause exemption revocation
A section 501(c)(3) organization served as a collective voice for health-care providers during changes in a local health-care system. It helped members influence rates and policies, advocated for…
Family-focused residential care causes exemption revocation
A private foundation operated a single-family home for one severely developmentally disabled person who was the chief executive's son. The organization also reported providing services for a period…
Annuity applicant appears to exceed exemption receipts limit
A foreign applicant sought exemption under section 501(c)(15) as an insurance company other than a life insurance company. It received large purchase payments under contracts labeled as deferred…
Hospital lease advances charity and avoids debt-financed treatment
A tax-exempt community hospital association planned to lease its hospital premises to a state university whose academic medical center would operate the facility. The lease required continued…
Large foundation grant qualifies as an unusual grant
A recently formed public charity supporting law enforcement received a large cash grant from an unrelated foundation for a pilot program involving media, community involvement, training, recognition…
Commercial clinical-trial operations fail the exemption test
An organization sought section 501(c)(3) status for multiple-sclerosis research and education. About 80 percent of its activities involved clinical trials sponsored by pharmaceutical companies,…
Payments benefiting board members' families defeat exemption
An organization sought section 501(c)(3) status to help families of children with a specific form of lymphoma. One of its three board members had a child whose name the organization used, and that…
Commercial LLC fails exemption and public-support tests
A sole-member limited liability company sought section 501(c)(3) exemption and section 509(a)(2) public-charity status. Its documents described managing related companies, tracking donated…
Condominium association is not a business league
A four-unit condominium association sought exemption as a business league under section 501(c)(6). It collected monthly assessments and used them for insurance, utilities, repairs, maintenance,…
Foundation's paid data services further its charitable mission
A private operating foundation collected and analyzed neighborhood data to improve the lives of low-income children and their families. It proposed charging social-sector organizations reasonable…
Lack of cash does not prevent accumulated earnings tax
A corporation held partnership interests and reported flow-through income, but the partnerships generally distributed only enough cash to cover the corporation's tax liabilities. The corporation…
Captive insurer denied section 501(c)(15) exemption
A foreign captive insurer sought recognition as tax exempt under section 501(c)(15). The IRS concluded that its primary and predominant activity was not insurance because most contracts covered…
Scholarship foundation denied exemption for serving private interests
A private foundation sought section 501(c)(3) exemption for a scholarship limited to National Merit Finalists from one high school who enrolled at a college about 3,000 miles away. The founders…
Veterans organization loses exemption after failing membership test
An organization recognized under section 501(c)(19) operated a social club with regular members and a much larger class of social members. The IRS found that only a redacted percentage of its total…
Medical aid charity reserved half its funds for one family
An organization sought section 501(c)(3) status to raise money for medical expenses of children with cancer or other life-threatening illnesses. It was originally formed to assist one named child…
Franchisee association is denied business-league exemption
An association formed by owners of stores operating under one franchise sought exemption as a business league under section 501(c)(6). Its membership, revenue, educational work, dispute-resolution…
Incomplete organizational record prevents section 501(c)(3) exemption
An applicant sought recognition as a section 501(c)(3) organization but did not provide an organizing document or a sufficiently detailed description of its proposed operations. Its filings…
Section 501(c)(3) status is revoked after no exempt activity
An organization had received recognition under section 501(c)(3), but its representative later stated that a scammer had induced the filing and that the organization never intended to apply for…
Charity loses exemption after withholding examination records
The IRS examined a section 501(c)(3) grant-making organization after its return reported grants and little or no public support. The organization supplied some information but repeatedly withheld…
Private-home restoration organization is denied exemption
An organization sought section 501(c)(3) status to obtain donations and grants for restoring a historic landmark owned and occupied by its incorporator and director. The owner would select and…
Single-beneficiary medical charity loses exemption
An organization was formed to raise money for one named individual's cancer-related medical care, transportation, hospice, home care, and other needs. The beneficiary's father served as trustee, the…
Inactive and dissolved organization loses exemption
A public charity reported that it had never become operational and had conducted no activities since receiving exemption. State records also showed that its corporate status had been dissolved. The…
Inactive nursing home charity loses exemption
A tax-exempt organization had operated a nursing home for elderly residents. It sold all of its assets, stopped providing nursing home care, and ceased all activity. The examination report stated…
Nursing home operator's exemption revoked after shutdown
A section 501(c)(3) organization had operated a nursing home for elderly residents. By the examined year, it had sold the nursing home and its other assets, stopped providing care, and ceased all…
Commingled funds and private benefit end exemption
A charity provided donated goods and social services, but its activities had declined substantially. Its president used a personal checking account as the organization's bank account, mixing…
Volunteer fire department loses labor organization status
A volunteer fire department reported on Form 990 that it was exempt as a labor, agricultural, or horticultural organization under § 501(c)(5). The IRS found that its objectives did not concern…
Charity loses exemption after withholding examination records
A recognized § 501(c)(3) organization did not provide records requested during an IRS examination. The IRS mailed an information request, visited the organization's facility, sent a second request…
Member services cost business league its exemption
An organization had been recognized as a business league under § 501(c)(6). It later developed and expanded a strategic initiative that provided particular services to members and constituted a…
Captive insurer lost section 501(c)(15) exemption
A foreign captive insurer had previously received recognition as a tax-exempt small insurance company under section 501(c)(15). After examining four tax years, the IRS concluded that most…
Coffee shop denied charity status for commercial operations
A nonprofit corporation opened a coffee shop to provide a gathering place, support Christian outreach, and eventually give profits to community organizations and people in need. The shop was open to…
Repeated missed examinations lead to loss of exemption
A recognized § 501(c)(3) organization filed Form 990-N and was selected for examination. The IRS repeatedly mailed information requests, called and emailed the organization's contacts, and scheduled…
Founder's personal expenses and missing records cost charity its exemption
A founder controlled a charitable foundation's operations, bank accounts, and spending. The IRS found that the foundation repeatedly paid the founder's personal expenses without contemporaneously…
Charity lost its exemption after failing to provide requested records
A charitable organization provided some financial records for one tax year but then stopped responding to IRS letters and phone calls seeking clarification, source documents, and records for another…
Inactive swim club no longer operated for social or recreational purposes
A former swim club sought recognition under § 501(c)(7) after its earlier exemption was automatically revoked for failing to file required returns. The pool had closed because of ground movement,…
Charity's asset sale, royalties, rent, and minority venture received favorable treatment
A charitable and educational organization sold certain assets to a new partnership, licensed intellectual property to the partnership, leased it office space, and held a minority interest through a…
Arts organization denied exemption for serving private interests
An arts organization sought section 501(c)(3) status to commission, perform, record, publish, and teach experimental music. Its governing documents and website focused on managing and producing the…
Youth ranch lost exemption for private benefit and inurement
A nonprofit operated a residential ranch program for boys with emotional and behavioral problems and had held section 501(c)(3) status since 2007. The IRS found that the organization paid ranch,…
Member-only facilities did not promote community social welfare
The IRS revoked an organization's section 501(c)(4) exemption for two tax years because its activities primarily served members rather than the public. The organization owned recreational…
Death-benefit association denied social club exemption
An association of people from the same foreign city sought exemption as a social club under section 501(c)(7). Members paid dues and additional required contributions so the association could help…
Medical office landlord denied exemption for commercial activity and private benefit
An organization sought section 501(c)(3) status to build and operate a medical office facility in a rural health professional shortage area. It planned to lease space and provide business services…
Young professionals group denied section 501(c)(3) status
An organization already exempt under section 501(c)(4) sought recognition under section 501(c)(3). It organized about 60 annual events for young professionals, including networking gatherings,…
Commercial food hub denied section 501(c)(3) status
An organization sought section 501(c)(3) status to operate food hubs connecting local farmers with restaurants and retailers. It planned to help farms plan production, then receive, repackage,…
IRS revokes exemption after organization refuses examination requests
The IRS opened an examination of a section 501(c)(3) organization and repeatedly requested records needed to evaluate its activities and continued qualification for exemption. An officer said the…
Private foundation loses exemption after undocumented personal expenditures
A private foundation stated that it would make grants to other section 501(c)(3) organizations and create an endowment for grantmaking. During the examined years, it made no documented grants and…
Organization loses exemption for nonexempt activities and private benefit
A tax-exempt organization promoted education and careers in a redacted field through member events, mentoring, advocacy, youth workshops, and grants. The IRS found that a substantial share of its…
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.