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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IRS proposes revoking a social club's tax exemption
The IRS proposed revoking an organization's exemption as a social club under IRC § 501(c)(7). The examination report states that the organization provided housing and related services to sorority…
IRS revokes a golf and country club's tax exemption
The IRS revoked a golf and country club's exemption under IRC § 501(c)(7). The examination report states that the club opened its golf course, restaurant, bar, pro shop, liquor service, and lessons…
IRS denies exemption to an organization operating a multiple listing service
The IRS issued a final adverse determination denying exemption under IRC § 501(c)(6) to an organization whose primary activity was operating a multiple listing service for real estate professionals.…
IRS denies exemption to an educational organization that benefited a related for-profit company
The IRS denied exemption under IRC § 501(c)(3) to an organization that assembled and distributed free educational courses and materials. The activities advanced education, but the organization was…
IRS denies exemption to a foreclosure referral organization
The IRS denied exemption under IRC § 501(c)(3) to an organization that referred homeowners to two for-profit affiliates for mortgage and foreclosure services. The organization received commissions…
IRS denies exemption to an internet security organization
The IRS denied exemption under IRC § 501(c)(3) to an organization that proposed to provide internet security services to civil society groups, bloggers, and other organizations, including in foreign…
IRS revokes an organization’s exemption for social activities and missing returns
The IRS revoked an organization’s exemption under IRC § 501(c)(3) because it operated primarily through social, recreational, and dining activities rather than exclusively for exempt purposes. The…
IRS revokes an organization’s exemption after it ceased operations
The IRS revoked an organization’s exemption under IRC § 501(c)(3) after finding that it had ceased operations and failed to establish that it was operating for an exempt purpose. The organization…
IRS proposes revoking exemption for failure to file a final return
The IRS proposed adjusting and revoking an organization’s exemption under IRC § 501(c)(3) after the organization failed to provide a final return needed to terminate its operations. The examination…
IRS proposes revoking a conservation easement organization’s exemption
The IRS proposed revoking exemption under IRC § 501(c)(3) for an organization that accepted conservation easements and related property transfers. The examination report concluded that the…
IRS proposes revoking exemption for charitable gaming activities
The IRS proposed revoking an organization’s exemption under IRC § 501(c)(3) after finding that its charitable gaming operations were not incidental to its exempt activities. The organization…
Community grocery cooperative denied section 501(c)(3) exemption
The IRS finalized its denial of tax-exempt status for a nonprofit community grocery cooperative. The organization planned to operate a grocery store, restaurant, bakery, and food-processing…
Organization denied section 501(c)(3) exemption for unclear and commercial activities
The IRS finalized an adverse determination denying exemption to an organization that described health and education advocacy, grantmaking, and community programs. The IRS found that the…
Political party organization denied section 501(c)(4) exemption
The IRS issued a final adverse determination to an organization that sought exemption under IRC § 501(c)(4). The organization promoted participation in a political party, endorsed party candidates,…
Public-policy advocacy organization denied section 501(c)(4) exemption
The IRS issued a final adverse determination to a research and advocacy organization that sought exemption under IRC § 501(c)(4). The organization planned to promote public-policy debate and…
Talmudic scholarship organization denied section 501(c)(3) exemption
The IRS issued a final adverse determination to a religious and educational organization that provided stipends to Talmudic scholars in a foreign country. The organization’s records showed payments…
Internet consulting organization denied section 501(c)(3) exemption
The IRS issued a final adverse determination to an organization that provided internet training, website development, and related consulting services to small and medium-sized businesses. The…
Foundation’s exemption revoked for failing the operational test
The IRS revoked a foundation’s exemption under IRC § 501(c)(3) after finding that it was not operating and therefore did not satisfy the operational test. The foundation had described music and arts…
IRS revoked a charity's section 501(c)(3) exemption
The IRS revoked an organization's tax exemption under section 501(c)(3). The IRS found that the organization did not operate exclusively for exempt purposes, commingled its account with the…
IRS revoked a foundation's section 501(c)(3) exemption
The IRS revoked a foundation's exemption under section 501(c)(3), effective January 1 of the redacted year. The foundation reported charitable services, but the IRS found that it could not produce…
IRS revokes an organization's tax-exempt status for private benefit and inurement
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(3), effective January 1 of the redacted year. The determination says the organization did not show that a substantial part…
IRS revokes a foundation's exempt status for inurement and private benefit
The IRS determined that a foundation did not qualify for exemption under IRC § 501(c)(3) because a substantial amount of its assets inured to the private benefit of its founders, officers, and…
IRS revokes an organization's exemption after failures to show exempt operations
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(3). The determination says the organization did not establish that it operated exclusively for exempt purposes or that its…
IRS denies exemption to a dental-benefits organization serving member companies
The IRS denied exemption under IRC § 501(c)(4) to an organization formed to develop dental-benefit products and related administration services for member companies of an association. The…
Determination 1350047: IRS revokes a trust's exemption after finding private inurement and disqualified-person control
The IRS reviewed a trust that sought exemption under IRC § 501(c)(3) and classification as a supporting organization under § 509(a)(3). The trust received donated real estate from its creators, then…
Determination 1350046: IRS revokes exemption for failure to keep records supporting charitable operations
The IRS revoked an organization's exemption under IRC § 501(c)(3) after an examination found that it did not keep adequate records of its income, receipts, and disbursements. The organization…
Determination 1350045: IRS revokes exemption after an organization becomes inactive
The IRS revoked an organization's exemption under IRC § 501(c)(3) after an examination found that it had not operated for several years and lacked sufficient funding to carry out the activities…
Determination 1350044: IRS denies exemption for fee-based mental-health services model
The IRS denied exemption under IRC § 501(c)(3) to a nonprofit that planned to arrange mental-health services through independent contractor physicians and partner agencies. The organization would…
Determination 1350043: IRS denies exemption for rural hospital management and private benefit
The IRS denied exemption under IRC § 501(c)(3) to an organization formed to support rural hospitals through management services, specialty medical lines, physician recruitment, and shared resources.…
Determination 1350042: IRS denies exemption for Internet donation services benefiting related businesses
The IRS denied exemption under IRC § 501(c)(3) to an organization that planned to process donations through a related for-profit e-commerce and social-networking website. The organization expected…
Determination 1350041: IRS revokes exemption for commingled finances and inadequate grant records
The IRS revoked an organization's exemption under IRC § 501(c)(3) after finding that its primary account was commingled with the founder's personal finances. The organization could not provide…
IRS proposes revocation of an organization's Section 501(c)(3) status
The IRS proposed revoking an organization's tax-exempt status under Section 501(c)(3). The examination found that the organization used a related for-profit entity to handle its day-to-day…
IRS revokes 501(c)(3) status for a fee-based debt management operation
The IRS issued a final adverse determination revoking an organization's exemption under Section 501(c)(3), effective June 1, 20XX. The organization mainly enrolled clients in debt management plans,…
IRS denies 501(c)(3) exemption for an open-source software website
The IRS denied a nonprofit organization's application for recognition under Section 501(c)(3). The organization maintained a website that distributed open-source computational fluid dynamics…
IRS revokes a forensic-examiner association's Section 501(c)(6) status
The IRS revoked an association's exemption under Section 501(c)(6), effective January 1, 20XX. The association represented forensic examiners, but a related for-profit company controlled its…
IRS changes an organization's foundation classification to Section 509(a)(2)
The IRS modified an organization's private-foundation classification, effective January 1, 20XX. The organization had previously been treated as publicly supported under Sections 509(a)(1) and…
IRS denies Section 501(c)(6) status to a proposed internet-standards league
The IRS denied an organization's application for exemption under Section 501(c)(6). The organization planned to develop and license a new internet standard for storing and controlling redacted…
IRS revokes a homeowners association's Section 501(c)(4) status
The IRS revoked a homeowners association's exemption under Section 501(c)(4), effective March 1, 20XX. The association restricted access to its common areas to members and their guests, using gates,…
IRS revokes exemption after organization ceases operations
The IRS revoked an organization's Section 501(c)(3) exemption effective December 31, 20XX. The organization had stopped operating, so it was no longer operated exclusively for an exempt purpose. The…
IRS revokes 501(c)(3) status for missing records and improper asset distribution
The IRS revoked an organization's Section 501(c)(3) exemption effective June 1, 20XX. The organization failed to produce records needed to show that it operated exclusively for exempt purposes,…
Determination 1347023: IRS denied § 501(c)(6) exemption to an organization promoting a related health-record system
The IRS denied an organization's application for exemption under IRC § 501(c)(6). The organization said it would improve health-data technology and support health-care education, standards, and…
IRS denies exemption to a professional management training organization under section 501(c)(3)
The IRS denied exemption under section 501(c)(3) to an organization that offered professional management training, certification, internships, and related programs. The organization worked closely…
PLR 1345034: IRS approves an early charitable distribution from a lead annuity trust
An irrevocable charitable lead annuity trust asked whether it could end early and distribute its remaining assets to a related private foundation after determining that it would run out of funds…
PLR 1345033: IRS approves an early charitable distribution from a lead annuity trust
An irrevocable charitable lead annuity trust asked whether it could end early and distribute its remaining assets to a related private foundation after determining that it would run out of funds…
IRS denies tax exemption to a financial education and housing organization
The IRS finalized its denial of tax-exempt status under IRC § 501(c)(3) after the organization did not protest a proposed adverse determination within 30 days. The proposed determination found that…
IRS denies exemption to a fundraising organization supporting a foreign charity
The IRS finalized its denial of tax-exempt status under IRC § 501(c)(3) after a U.S. fundraising organization did not protest a proposed adverse determination within 30 days. The organization raised…
IRS denies exemption to an open software standards organization
The IRS finalized its denial of tax-exempt status under IRC § 501(c)(3) after an organization promoting an open software standard did not protest a proposed adverse determination within 30 days. The…
Other 1344011: IRS revokes a social club's exempt status after recurring public bingo income
The IRS issued a final determination revoking a social club's exemption under IRC § 501(c)(7). The organization operated charitable bingo open to the general public, including traditional and…
IRS determination 1344010: Social club exemption revoked for excessive nonmember income
The IRS revoked a social club's exemption under section 501(c)(7) after finding that recurring nonmember income exceeded the applicable 15 percent limitation. The income came from nonmember use of…
Determination 1343028: IRS revokes exempt status after finding private benefit to a related for-profit business
The IRS revoked a nonprofit organization's exemption under IRC § 501(c)(3), effective January 1, 2008. The organization hosted high school sporting events and provided scholarships, while a related…
Determination 1343026: exemption revoked after a small insurer fails the premium-income test
The IRS revoked a small insurance company's exemption under IRC § 501(c)(15), effective January 1, 20xx. The corporation's gross receipts were below the $600,000 ceiling, but its receipts did not…
Other 1343025: IRS revokes a social club's exempt status after nonmember activity and recordkeeping failures
The IRS revoked a social club's exemption under IRC § 501(c)(7). The examination found substantial use of the club's facilities by nonmembers, public advertising, and inadequate records for…
Other 1343024: IRS revokes a golf club's exemption for public use of its facilities
The IRS revoked a golf and country club's exemption under IRC § 501(c)(7). The club advertised that golfing was open to the public, rented its banquet and snack-bar facilities to a for-profit…
Determination 1342014: social club exemption revoked after public receipts exceed the permitted limit
The IRS revoked a social club's exemption under IRC § 501(c)(7), effective January 1, 20xx. The club maintained a lodge and promoted hunting, fishing, and sportsmanship for its members, but it also…
Other 1342013: IRS revokes an insurance association's tax exemption after it fails the premium-income test
The IRS revoked an insurance association's exemption under IRC § 501(c)(15), effective January 1, 2007. The organization provided burial certificates and had gross receipts below the statutory…
Other 1342012: IRS revokes an insurer's tax exemption while it winds down old claims
The IRS revoked an insurance company's exemption under IRC § 501(c)(15) for the specified years. The company had stopped accepting new or renewal business and was operating to resolve existing…
PLR 1342011: A bequest qualifies as an unusual grant for a camp serving seriously ill children
A publicly supported organization that operates a camp for seriously ill children asked whether a proposed charitable bequest would qualify as an unusual grant. The IRS concluded that it could be…
IRS revokes an organization's section 501(c)(3) exemption after finding no charitable activity
The IRS issued a final adverse determination revoking an organization's tax-exempt status under section 501(c)(3), effective January 1, 20XX. The IRS concluded that the organization had not…
IRS revokes an insurance organization's section 501(c)(15) exemption after controlled-group receipts exceeded the limit
The IRS revoked an insurance organization's exemption under section 501(c)(15), effective January 1, 20xx. The examination report concluded that the organization's gross receipts, when combined with…
IRS revokes a mutual insurance organization's section 501(c)(15) exemption
The IRS revoked a mutual insurance organization's exemption under section 501(c)(15), effective January 1, 20xx. The examination report concluded that the organization did not meet the statutory…
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.