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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Determination 201007075: IRS revokes an organization's exemption after it failed to provide records for examination
The IRS revoked an organization's exemption under IRC § 501(c)(3) after the organization failed to provide documents and records needed to examine its receipts, expenditures, and activities. The…
Determination 201007074: IRS revokes an organization's exemption after it failed to provide records for examination
The IRS revoked an organization's exemption under IRC § 501(c)(3) after the organization failed to provide documents and records needed to examine its receipts, expenditures, and activities. The…
Determination 201007073: IRS revokes an organization's exemption after it failed to file returns and maintain qualifying activities
The IRS revoked an organization's exemption under IRC § 501(c)(3) after an examination found that it had not conducted tax-exempt activities, had not filed required Form 990 returns, and had failed…
Determination 201007072: IRS revoked an organization's section 501(c)(3) exemption
The IRS issued a final adverse determination revoking an organization's exemption under section 501(c)(3), effective January 1, 20XX. The IRS said the organization did not provide enough information…
Determination 201007071: IRS revoked a social club's section 501(c)(7) exemption
The IRS revoked a social club's section 501(c)(7) exemption after finding that the club served the general public, received nonmember income above the applicable limit, and did not maintain adequate…
Determination 201007070: IRS revoked an organization's section 501(c)(3) exemption
The IRS revoked an organization's section 501(c)(3) exemption effective October 7, 20XX. The organization had not provided records needed to examine its Form 990 and had not filed prior Form 990…
Determination 201007069: IRS revoked exemption for a seller-funded homebuyer assistance program
The IRS revoked an organization's section 501(c)(3) exemption effective January 1, 20XX. The organization provided down-payment assistance to low-income homebuyers, but funded the assistance mainly…
Determination 201007068: IRS revoked exemption after records and filing failures
The IRS revoked an organization's section 501(c)(3) exemption effective February 1, 20XX. The organization did not provide records needed for an examination of its Form 990 and had not filed prior…
PLR 201007067: IRS approved Internet and TV services for a rural telephone cooperative
The IRS considered whether a rural telephone cooperative could offer Internet and television services over the same copper-wire network used for telephone service. It ruled that both services were…
PLR 201007066: IRS extended the period to dispose of a private foundation's excess business holdings
The IRS granted a private foundation an additional five years to dispose of stock it received as a donation and treated as excess business holdings. The foundation had tried to sell the holdings…
PLR 201007065: Private foundation transfer approved with limits on attributes and expenditure responsibility
The IRS approved a private foundation’s plan to transfer cash and marketable securities worth about one-third of its assets to a newly recognized private foundation. The transfer qualified as a…
PLR 201007064: Private foundation transfer approved with limits on attributes and expenditure responsibility
The IRS approved a private foundation's plan to transfer cash and marketable securities worth about one-third of its assets to another private foundation. The transfer qualified as a significant…
PLR 201007063: IRS ruled that a charitable organization's pooled-fund contracts would not create unrelated business taxable income
The IRS ruled that a publicly supported charitable organization could issue contractual units in its pooled investment fund to charitable remainder trusts for which it served as trustee and…
PLR 201007062: IRS extended a private foundation's period to dispose of excess business holdings
The IRS granted a private operating foundation an additional five years to dispose of a 20.6 percent profits interest in a radio-station partnership. The interest was received by contribution and…
PLR 201007061: IRS waived the 60-day rollover requirement after an advisor's error
The IRS waived the 60-day deadline for a taxpayer to roll a retirement-plan distribution into an IRA. The taxpayer deposited the distribution with a financial company within the 60-day period, but…
IRS denied exemption to an entertainment-industry website organization
The IRS denied an organization's application for recognition under section 501(c)(3). The organization planned to operate a paid website offering profiles, calendars, communication tools, and…
Released levy does not end the taxpayer's notice and hearing rights
Chief Counsel advised that the IRS should still send Letter 1058-D to a taxpayer after releasing a levy. The release of a levy does not end the taxpayer's statutory right to notice and a Collection…
Do not use one taxpayer's case as an example without consent
Chief Counsel advised against using one taxpayer's case as an example for training or in an annual report unless the taxpayer consented. The advice explained that return information under section…
Loss issues under section 465 may require partnership and partner-level determinations
Chief Counsel advised that the IRS should assess losses disallowed at the partnership level and then issue affected-item notices for additional losses disallowed under section 465. The advice…
Six-year assessment period may apply to an adequately undisclosed income omission
Chief Counsel advised that the IRS may use the six-year assessment period under section 6229(c)(2) even when that period extends beyond the one-year suspension period in section 6229(d). The advice…
An AAR overassessment may be abated if it has not been paid
Chief Counsel advised that the IRS could consider abating an overassessment if the taxpayers had not yet paid it. The advice also stated that examining a partnership's books and records without…
A normal Form 872 covers non-TEFRA partnership items
Chief Counsel advised that a normal Form 872 consent to extend the assessment period covered items from partnerships that were not subject to the TEFRA provisions. The advice addressed the wording…
Rental income from allotted trust land was treated as directly derived from the land
Chief Counsel advised that rent received by tribal members from leases of allotted, restricted federal trust land was reasonably viewed as derived directly from the land and therefore exempt from…
IRS approved tax treatment for a merger, stock exchange, and redemption
The IRS ruled on a proposed transaction in which two shareholders would form a new corporation, contribute their stock to it, and merge it into the existing corporation. Minority shareholders would…
IRS approved tax treatment for a merger, stock exchange, and redemption
The IRS ruled on a proposed transaction in which two shareholders would form a new corporation, contribute their stock to it, and merge it into the existing corporation. Minority shareholders would…
PLR 201007050: IRS addressed control and subsidiary contributions in a planned corporate split-off
The IRS considered a proposed series of corporate transactions involving a public parent, its subsidiary, and a controlled corporation. The plan included an internal distribution of the controlled…
PLR 201007049: IRS granted late S corporation election relief for inadvertent filing failure
The IRS granted a corporation relief for failing to timely file an election to be treated as an S corporation. The corporation's shareholder intended the election to be effective on the…
PLR 201007048: IRS granted an extension for a taxable REIT subsidiary election
The IRS granted a real estate investment trust and a corporation an extension of time to make a joint election to treat the corporation as a taxable REIT subsidiary. The parties intended to make the…
PLR 201007047: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible to make the election…
PLR 201007046: IRS treated a late S corporation election as timely
The IRS granted a corporation relief for failing to timely file Form 2553, its election to be treated as an S corporation. The corporation's sole shareholder intended the election to be effective on…
PLR 201007045: IRS approved a qualified stock purchase and related § 338(h)(10) election
The IRS considered a proposed transaction in which a parent corporation would transfer stock of a wholly owned subsidiary to an LLC in exchange for preferred interests, then transfer those interests…
PLR 201007044: IRS treated a controlled foreign corporation's Subpart F income as qualifying RIC income
The IRS ruled that Subpart F income from a regulated investment company's wholly owned controlled foreign corporation would count as qualifying income for the investment company's 90-percent…
PLR 201007043: IRS approved a downstream merger as a Type F reorganization
The IRS considered a proposed downstream merger in which an S corporation would merge into its wholly owned subsidiary, with the subsidiary surviving. The shareholder ownership would remain the…
PLR 201007042: IRS granted relief for a late S corporation election
The IRS granted a corporation relief for failing to timely file Form 2553, its election to be treated as an S corporation. The corporation's shareholders intended the election to be effective on a…
PLR 201007041: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended the election to be effective…
PLR 201007040: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended the election to be effective…
PLR 201007039: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended the election to be effective…
PLR 201007038: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended the election to be effective…
PLR 201007037: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be classified as a disregarded entity for federal tax purposes. The entity intended the election to be effective…
PLR 201007036: IRS granted extra time for a foreign entity to elect partnership status
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be classified as a partnership for federal tax purposes. The entity intended the election to be effective on a…
PLR 201007035: IRS permitted revocation of an election out of installment reporting
The IRS permitted a taxpayer to revoke an election out of installment-method reporting for two property sales. The taxpayer's accountant had reported all of the gain on the original return instead…
PLR 201007034: IRS granted extra time for a foreign entity to elect corporate treatment
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity had one…
PLR 201007033: IRS granted extra time for a foreign entity to elect partnership status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was eligible for the classification but…
PLR 201007032: IRS granted extra time for a foreign entity to elect partnership status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity was eligible for the classification but…
PLR 201007031: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007030: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007029: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007028: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007027: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007026: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007025: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007024: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007023: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007022: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007021: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007020: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007019: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007018: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007017: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
PLR 201007016: IRS granted extra time for a foreign entity to elect disregarded-entity status
The IRS granted a foreign eligible entity an extension of time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended the election to be…
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.