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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PLR 201041017: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 201041016: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 201041015: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 201041014: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 201041013: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 201041012: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 201041011: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 201041010: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 201041009: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 201041008: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 201041007: The IRS granted more time for a split-dollar loan representation
The IRS granted a taxpayer up to 30 days to prepare and sign a written representation concerning nonrecourse split-dollar life insurance loans. The representation states that a reasonable person…
PLR 201041006: The IRS granted more time for split-dollar loan representations
The IRS granted a subsidiary up to 30 days to prepare and sign written representations concerning nonrecourse split-dollar life insurance loans made to employee participants. The representations…
PLR 201041005: The IRS allowed a taxpayer to revoke an election out of installment reporting
A taxpayer sold rental property through an exchange company and received a note as part of the consideration. The taxpayer's return preparer reported all of the gain immediately, which treated the…
PLR 201041004: The IRS classified a cooperative's grain payments as per-unit retain allocations
The IRS ruled that a farmers' cooperative's cash payments to members for grain marketed through the cooperative were per-unit retain allocations paid in money under IRC § 1382(b)(3) and § 1388(f).…
PLR 201041003: The IRS classified disability and survivor benefits under section 104(a)(1)
The IRS ruled on the tax treatment of disability and survivor benefits paid under two public employee plans for line-of-duty injuries and deaths. It treated specified disability benefits and…
PLR 201041002: The IRS classified a cooperative's crop payments as per-unit retain allocations
The IRS ruled that a farmers' cooperative's cash payments to members for grain and another agricultural crop were per-unit retain allocations paid in money under IRC § 1382(b)(3) and § 1388(f). The…
PLR 201041001: The IRS granted late S corporation election relief after a QSub issue
The IRS granted a corporation relief for a late election to be treated as an S corporation. The corporation had previously been a qualified subchapter S subsidiary, but an ownership change created…
PLR 201040043: The IRS approved a five-year extension for a pension plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applied to eligible amortization charge bases established as of July 1, 2009,…
PLR 201040042: The IRS approved a five-year extension for a pension plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applied to eligible amortization charge bases established as of July 1, 2009,…
PLR 201040041: The IRS waived the 60-day IRA rollover requirement
The IRS waived the 60-day rollover requirement for a taxpayer who moved a distribution from an IRA into an account at a real estate limited partnership that could not legally serve as an IRA…
PLR 201040040: The IRS approved a five-year extension for a pension plan's unfunded liabilities
The IRS approved a plan's request for a five-year automatic extension to amortize unfunded liabilities. The extension applied to eligible amortization charge bases established as of July 1, 2009,…
PLR 201040039: The IRS waived the 60-day IRA rollover requirement after a bank error
The IRS waived the 60-day rollover requirement for a taxpayer whose financial institution mistakenly opened a non-IRA account instead of an IRA account. The taxpayer met with the institution during…
IRS revokes an organization's Section 501(c)(3) exemption for failing to provide records
The IRS revoked an organization's tax-exempt status under Section 501(c)(3), effective January 1, 20XX. The organization failed to respond to repeated requests for records and failed to file the…
Determination 201040037: IRS revokes a social club's tax exemption
The IRS revoked a social club's federal income tax exemption under IRC § 501(c)(7), effective 10/1/XX. The determination says the club had closed, had no books and records available for examination,…
Determination 201040036: IRS revokes exemption from a social and recreational organization
The IRS revoked an organization's federal income tax exemption under IRC § 501(c)(3), effective August 9, 20XX. The organization had been formed to promote minority family travel and camping…
Determination 201040035: IRS revokes an organization's tax exemption
The IRS revoked an organization's federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The final letter states that the organization was not operated exclusively for an…
Determination 201040034: IRS revokes a fraternal organization's exemption
The IRS revoked an organization's exemption under IRC § 501(c)(10), effective September 1, 20XX. The organization operated a bar and claimed to be a subordinate of a fraternal parent organization,…
Determination 201040033: IRS revokes a dissolved organization's exemption
The IRS revoked an organization's federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization had filed a final Form 990 with zeros on every line, did not file…
Determination 201040032: IRS revokes an organization’s tax exemption for lack of records
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective July 1, 20XX. The organization did not respond to repeated requests for records concerning its…
Determination 201040031: IRS revokes an organization’s tax exemption for lack of evidence
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective July 1, 20XX. The organization had not filed its required Form 990 and did not respond to repeated…
Determination 201040030: IRS revokes exemption from an education and research organization
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization was formed for Southeastern Indian education, research, and public…
Determination 201040029: IRS revokes an organization’s tax exemption for failure to respond
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization failed to provide information about its receipts, expenditures, or…
Determination 201040028: IRS revokes a dormant organization’s tax exemption
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization had ceased operations for several years and had been…
Determination 201040027: IRS revoked a dissolved organization's section 501(c)(3) exemption
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization had ceased operating, failed to keep required records, and failed to…
Determination 201040026: IRS revoked an organization’s section 501(c)(3) exemption after finding substantial non-exempt activities
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization’s activities included drum practice, bingo and other charitable…
Determination 201040025: IRS revoked a debt-management organization’s section 501(c)(3) exemption
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization’s primary activity was soliciting clients by telephone for debt…
Determination 201040024: IRS revoked an organization’s section 501(c)(3) exemption after finding a commercial purpose
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization had been recognized as tax-exempt but operated and described itself…
Determination 201040023: IRS revoked an organization’s section 501(c)(3) exemption for failing to file required returns
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective October 1, 20XX. The organization was formed to assist in locating missing children and had been…
Determination 201040022: IRS revoked a private foundation’s section 501(c)(3) exemption after loans benefited insiders
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 19XX. The organization was a supporting organization that distributed some income as grants…
PLR 201040021: IRS ruled that returning assets from an invalid charitable remainder trust would not trigger private-foundation taxes
The IRS ruled that a trust could return its assets to the donors without creating self-dealing or taxable-expenditure liability, and without triggering the tax on termination of private-foundation…
Determination 201040020: IRS denied section 501(c)(6) exemption for an automobile dealer advertising association
The IRS denied exemption under IRC § 501(c)(6) to an association whose members were automobile dealers selling specific vehicle brands. The association’s purpose was to advertise and promote those…
Determination 201040019: IRS denied section 501(c)(4) exemption to a developer-controlled homeowners association
The IRS denied exemption under IRC § 501(c)(4) to a homeowners association serving a residential development. The association planned to maintain common areas and collect equal assessments from unit…
CCA 201040018: Section 419 limits severance reserves to incurred claims and reasonable actuarial needs
Chief Counsel Advice considered whether an employer could deduct contributions to a welfare benefit trust for anticipated severance and vacation payments under IRC §§ 419 and 419A. The advice…
CCA 201040017: Treasury Regulation section 301.6402-4 controlled withholding refund scenarios
Chief Counsel Advice stated that a general counsel memorandum had no precedential value and must not be cited as authority in withholding refund scenarios. It advised that Treas. Reg. § 301.6402-4…
CCA 201040016: The IRS advised removing a section 6662A penalty from a Form 5330 notice
Chief Counsel Advice addressed whether the accuracy-related penalty under IRC § 6662A could apply to tax outside the income tax or subtitle A. Without an explanation supporting that application, the…
CCA 201040015: IRC sections 6103(h) and 6103(e) governed partner disclosures in a non-TEFRA audit
Chief Counsel Advice stated that disclosure of partner information during an audit of a non-TEFRA partnership was governed by IRC §§ 6103(h) and 6103(e). It advised that disclosure was permitted if…
CCA 201040014: A valid POA could provide partnership and partner information to the IRS
Chief Counsel Advice stated that a valid power of attorney for a non-TEFRA partnership could provide the IRS with any and all information about the partnership and its partners. It advised that a…
CCA 201040013: Trade or business income must be separated from investment income for self-employment tax
Chief Counsel Advice stated that self-employment income is trade or business income, not investment income. It advised separating the amount of trade or business income that would be subject to…
CCA 201040012: Health coverage for a dependent domestic partner was not FUTA wages
Chief Counsel Advice addressed whether a domestic partner who was an employee's dependent under IRC § 152 could be treated as a dependent for the FUTA exclusion. Counsel concluded that the FICA and…
CCA 201040011: A state-authorized person should sign for an LLC tax matters partner
Chief Counsel Advice stated that, because the tax matters partner was an LLC, a person authorized under state law should sign on behalf of the LLC. It directed the reader to page 10 of Notice…
CCA 201040010: Tax matters partner status did not give an LLC representative state-law signing authority
Chief Counsel Advice stated that Notice CC-2009-027, page 10, superseded the cited Internal Revenue Manual provision concerning who could sign for a tax matters partner. It explained that an LLC may…
CCA 201040009: Partnership items converted when a receiver was appointed
Chief Counsel Advice stated that Treas. Reg. § 301.6231(c)-7(b) provides for conversion of a partner's partnership items when a receiver has been appointed in a receivership proceeding. The…
CCA 201040008: Section 6231(g) could apply TEFRA rules to the covered period
Chief Counsel Advice stated that, if only one partnership return was filed and it was facially subject to the TEFRA provisions, IRC § 6231(g) would make the TEFRA partnership provisions apply to the…
CCA 201040007: Foreign tax credits for shareholder-level withholding taxes
Chief Counsel Advice addressed foreign tax credits when a foreign corporation pays a dividend to a domestic corporate shareholder that owns at least 10 percent. Corporate-level foreign taxes that…
CCA 201040006: Section 6662A did not appear to apply outside income tax or subtitle A
Chief Counsel Advice considered whether the section 6662A penalty applies to excise taxes. The advice stated that it did not see how section 6662A would apply to a tax outside income tax or subtitle…
CCA 201040005: Taxpayers could challenge carryback liabilities in a CDP hearing
Chief Counsel Advice addressed whether taxpayers could challenge their underlying tax liability during a collection due process hearing. The Service had summarily assessed liabilities from excessive…
CCA 201040004: An AVA designation can be an amortizable section 197 intangible
Chief Counsel Advice considered whether the amount allocated to an American viticultural area designation when purchasing a vineyard could be amortized under IRC § 197. It concluded that the…
PLR 201040003: Retiree health trust income excluded under section 115
The IRS ruled that a trust funded by a city to provide health benefits to the city's eligible retirees and their dependents performs an essential governmental function. As of the effective date of a…
PLR 201040002: Late S corporation election treated as timely
The IRS granted a corporation relief for a late election to be treated as an S corporation. The corporation intended the election to be effective on its incorporation date but did not file it on…
PLR 201040001: Inadvertent S corporation termination relief
The IRS ruled that a corporation's S corporation election terminated when a shareholder became a nonresident alien and therefore became an ineligible shareholder. Because the termination was…
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.