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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
Veterans organization loses exemption over unsupported gift-in-kind activities
A veterans organization was recognized as exempt based on plans to provide training, job-placement help, and related support. Its return later described assistance to disabled and homeless veterans,…
Social club loses exemption after recurring public-use income exceeds 15 percent
A social and recreational club regularly opened its dance and bowling activities to nonmembers, who could enter through an unlocked gate and pay a nonmember fee at the counter. Its nonmember…
Weekly campus market is an unrelated business and vendor fees are not rent
An alumni-support organization operated a public market every weekend on a community college’s parking lots and derived substantially all of its revenue from vendor fees. The organization used the…
Exemption revoked for private benefit and lack of charitable control
The IRS revoked a religious grantmaking organization’s section 501(c)(3) status retroactively to its formation. The organization’s sole significant asset was a nonvoting limited-partnership interest…
Field office facts may support a technical advice request
Chief Counsel responded to a question about the statement of facts for a technical advice request. The email quoted Revenue Procedure 2015-2, which requires the field office to submit its…
Charity's exemption revoked because its founder's telemarketing firm captured the donations
A health-awareness charity was founded by the sole owner of a telemarketing company, and it hired that same company as its only professional fundraiser. Nearly all the money raised flowed straight…
Exemption revoked for commercial debt-management operations
The IRS revoked a consumer credit-counseling organization’s section 501(c)(3) status. The organization operated an inbound call center whose primary activity was enrolling consumers in fee-based…
Exemption denied for commercial healing services and private benefit
An organization sought section 501(c)(3) status for healing services involving people and animals, free work for animal rescues, retreats, workshops, and outreach. The IRS found that a substantial…
Franchisee association denied business-league exemption
An association of franchise store owners sought exemption as a business league under section 501(c)(6). Its activities focused on increasing members’ sales through brand-specific advertising,…
Pet-care business denied charitable exemption
An organization succeeded a for-profit pet boarding and veterinary business and sought section 501(c)(3) status. It planned some public education, reduced-cost services for rescue animals, and…
Exemption revoked after failure to provide records
The IRS revoked an organization's section 501(c)(3) status after it did not respond to requests for information about its finances and activities. Without those records, the organization did not…
Exemption revoked for private benefit and inadequate grant controls
The IRS revoked an organization's section 501(c)(3) status after finding that substantial activities served private interests rather than exempt purposes. The organization collected and transferred…
HMO loses charity status after commercial expansion
A nonprofit health maintenance organization had originally served recipients of government health benefits. After a merger, it added a substantial commercial line whose premiums came from individual…
Healing institute loses exemption over private benefit
A nonprofit institute offered alternative-health treatments, classes, certifications, books, and other products based on a method created by its founder. Its returns reported unrelated business…
Medical-device developer denied charitable exemption
A membership organization of medical-device professionals sought recognition as a section 501(c)(3) charity. It planned to counsel inventors, develop and commercialize devices for underserved…
Market-rate consulting fails exemption tests
An organization sought section 501(c)(3) status for mediation, quality-management consulting, hospital-accreditation preparation, internal auditing, and services involving veterans and older people.…
Exemption denied for market-oriented real estate activities
A nonprofit corporation proposed to spend most of its time and money buying, rehabilitating, selling, and leasing real property. It did not limit all customers to a charitable class, establish…
Child-care charity lost exemption after shifting to resale operations
An organization had received section 501(c)(3) status to operate a child-care center for low-income families. It later closed the child-care facility, distributed its physical assets to other exempt…
Exemption revoked after operations ceased and records were withheld
A public charity had been recognized to support children and their families through financial, medical, educational, and in-kind assistance. During examination, the IRS repeatedly requested…
Exemption revoked because organization funds benefited its president
A religious organization conducted concert tours through its president, an ordained minister and musician. The IRS examination found that organization funds paid the president's personal expenses…
Open-source media software group denied exemption
A nonprofit developed and distributed free, open-source tools for transcribing, indexing, editing, and remixing online audio and video. Its software could be used for any purpose, including…
VEBA may fund health benefits for active employees
A voluntary employees' beneficiary association held trust assets for retirees' health benefits. It proposed amending its trust agreement to add active employees as eligible participants and to…
Environmental-claim financing organization loses exemption
A nonprofit bought approved reimbursement claims from owners and contractors cleaning up leaking underground fuel tanks, giving them cash before state environmental funds paid the claims. The…
Golf and recreation facility denied exemption
An employee association formed a new corporation that would receive and operate its recreational park, including a golf course, restaurant, sports facilities, rentals, and event services. Although…
Housing cooperative denied exemption
A cooperative apartment corporation sought section 501(c)(3) status to provide moderately priced housing to people age 55 or older. Members bought stock tied to particular apartments, paid monthly…
Campground restaurant denied social-club exemption
A mutual-benefit corporation sought section 501(c)(7) status for a restaurant serving campground visitors, local residents, members, and their guests. Its two directors also owned and managed part…
Business-referral network denied exemption
A membership association sought section 501(c)(6) status for a business-referral network. It admitted only one noncompeting member from each trade or profession and required members to exchange…
Inactive business league loses section 501(c)(6) status
A notary-related organization had been recognized as exempt under section 501(c)(6), but the IRS could not verify that it still operated as a business league. Examination letters were undeliverable,…
Organization loses section 501(c)(3) status for blocking examination
The IRS repeatedly tried to examine an organization's Form 990 and supporting records. Its president acknowledged some correspondence and agreed to appointments, but the organization produced no…
Voluntary-repatriation organization denied charitable status
An organization sought recognition as a charity for a program that would pay travel and related costs for undocumented immigrants who voluntarily returned to their home countries. It also intended…
Seller-funded down payment program loses charitable exemption
A tax-exempt organization operated a nationwide down payment assistance program for home purchases. Sellers and builders had to pay the organization an amount equal to the assistance provided to a…
Inactive religious radio station loses charitable exemption
A tax-exempt organization had operated a radio station broadcasting religious programs for Spanish-speaking listeners. Its president told the IRS that the organization had been inactive since a…
Private road association denied charitable exemption
A membership corporation applied for section 501(c)(3) status so it could acquire a road easement, build a private road, and maintain the road for its members. Membership was limited to owners of…
Grief-support publisher denied charitable exemption
An organization supporting grieving people applied for exemption while operating publishing, manufacturing, support, meal, and housing programs. Publishing and manufacturing accounted for 75 percent…
Inactive community-facility organization loses exemption
A tax-exempt organization had been formed to plan, fund, construct, manage, and maintain a mixed-use community facility. During an examination of its Form 990, the organization repeatedly failed to…
Nonresponsive civic organization loses exemption
A tax-exempt organization had been formed to encourage and promote diversity, dignity, and the inherent worth of people in a city. During an examination, the IRS repeatedly tried to obtain records…
Investment-focused company lost section 501(c)(15) exemption
The organization had been recognized as a tax-exempt small nonlife insurance company under section 501(c)(15). The IRS examination found that investment and related-party transactions were its…
For-profit construction operation denied 501(c)(3) exemption
A for-profit stock corporation sought section 501(c)(3) status for a program that would train ex-felons through highway construction, hauling, debris removal, and related work. It planned to bid for…
Business consulting operation denied 501(c)(3) exemption
An organization applied for section 501(c)(3) status to provide grant writing, business consulting, fiscal-agent services, training, payroll assistance, and other support. It served individuals,…
Organization lost exemption for private benefit and political activity
An organization formed to promote changes in the legal system operated through a newsletter, a website, and unrelated business activities managed by its president. The IRS examination found…
Bishop-campaign organization denied charitable exemption
A religious organization arranged preaching engagements, distributed campaign materials, solicited donations, and held fundraisers to support its pastor and board chair’s campaign for bishop of a…
One-party political symposium denied charitable exemption
An organization planned an educational symposium featuring more than 15 politicians, judges, and policy experts, all apparently affiliated with one political party. Its records focused on recruiting…
Animal therapy organization loses exemption for private inurement and lack of exempt activity
A section 501(c)(3) organization previously operated an animal-assisted therapy facility and sold its horse-therapy property to another exempt organization. The IRS found that mortgage proceeds from…
Reincorporated business league cannot use predecessor's exemption letter
A business league had been recognized as exempt under section 501(c)(6), then dissolved its original corporation and reincorporated in another state. The new corporation continued substantially the…
Seller-funded down payment program loses charitable exemption
A tax-exempt organization operated a down payment assistance program that gave buyers funds while requiring participating home sellers to pay the same amount plus an administrative fee. Although its…
Charity loses exemption over unsubstantiated overseas payments
A domestic charity primarily sent money to a related foreign organization that operated schools. The IRS found missing checks, wire-transfer records, bank statements, and other documentation for…
Organization serving one named child is denied exemption
An organization was created solely to raise funds for the treatment, education, and therapy of one named child with autism. The child’s parents were its only directors, its organizing document…
Foreclosure counseling organization denied exemption
An organization offered free foreclosure-prevention counseling and helped homeowners prepare and pursue loan modifications. It had abandoned its proposed classes and broader housing programs, did…
Low-income housing trust denied exemption for inadequate records
A charitable trust owned a 200-unit apartment complex donated by an LLC owned by its married founders and trustees, subject to a substantial loan and other liabilities. Although the trust proposed…
Inactive organization loses charitable exemption
An organization reported that it had been inactive for several years, had no operations or financial activity planned, and had entered bankruptcy. It did not respond to certified audit…
Inactive gift-annuity charity loses exemption after payments stop
A charity originally formed to support cancer patients later shifted to marketing charitable gift annuities. Many annuities were unsecured or uninsured, and funds from new investors were used to…
Recreational-residence association loses social welfare exemption
The IRS revoked the section 501(c)(4) exemption of an association serving owners of recreational residences on National Forest land. The association installed and maintained a water chlorination…
Dance troupe denied exemption for private studio and member benefits
A nonprofit dance troupe sought retroactive reinstatement of section 501(c)(3) status after its prior exemption was automatically revoked for failing to file Form 990 for three consecutive years.…
Insurer loses exemption but receives retroactivity relief
An insurance and reinsurance company asked whether it qualified for exemption under section 501(c)(15) for three tax years and whether it should receive relief from retroactive revocation under…
Social club loses exemption for recurring public business
A section 501(c)(7) social club rented its second-floor dance hall to a salsa club on recurring weeknights and weekends. Nonmembers could use the dance hall, bar, and restaurant, and the salsa club…
Social club loses exemption after relying on investment income
A section 501(c)(7) social club sold its real estate and personal property, invested the proceeds, and received no membership dues during the three examined years. Investment income supplied 100% of…
Environmental T-shirt seller loses exemption over commercial activity and private inurement
A section 501(c)(3) organization said it educated the public about environmental issues through public booths, pamphlets, cleanup programs, and message-bearing T-shirts. The IRS examination found…
Breast cancer charity loses exemption after family insiders use funds personally
A section 501(c)(3) organization provided financial and practical assistance related to breast cancer screening, treatment, and recovery. Most of its revenue came from professional fundraising, but…
Unresponsive charity loses exemption for failing to provide records
The IRS selected a section 501(c)(3) organization for examination of its annual information return. Repeated telephone calls, certified letters, and searches for updated addresses did not produce a…
Condominium fundraising foundation loses exemption for serving residents' private interests
A foundation was formed so condominium owners could make deductible contributions for projects outside their homeowners association's operating budget. Its money paid for improvements and services…
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.