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 revokes a fraternal organization's exemption after it failed to provide examination records
The IRS revoked an organization's exemption under section 501(c)(10). The organization was repeatedly asked to provide books, records, and other information needed to examine whether it continued to…
IRS denies section 501(c)(3) exemption to a community organization that did not substantiate its programs
The IRS issued a final adverse determination denying a community organization's application for exemption under section 501(c)(3). The organization proposed housing assistance, financial and…
IRS denies exemption to a nonprofit software licensor serving news organizations
The IRS denied a nonprofit corporation's application for section 501(c)(3) exemption. The corporation planned to develop and license publishing software to selected news organizations for fees,…
PLR 1340017: IRS approves a cooperative's accelerated retirement of former members' capital credits
The IRS ruled that a rural electric cooperative could accelerate the retirement of former members’ capital-credit accounts by offsetting those credits against unpaid electric-service balances. The…
Determination 1338059: IRS revokes exemption after organization funded private professional-association event
The IRS issued a final adverse determination revoking an organization’s exemption under section 501(c)(3), effective November 30, 2009. The organization’s reported activity was funding an annual…
Determination 1338055: IRS revokes office-condominium association’s section 501(c)(4) exemption
The IRS revoked an office-condominium owners association’s exemption under section 501(c)(4), effective January 1 of the redacted year. The organization collected membership dues to manage and…
Determination 1338054: IRS revokes exemption after organization failed to provide records
The IRS revoked an organization’s section 501(c)(3) exemption effective October 1 of the redacted year. The organization failed to respond to repeated reasonable requests for records needed to…
Determination 1338053: IRS denies social-welfare exemption for fee-based investor network
The IRS issued a final adverse determination for an organization that connected member entrepreneurs with member investors seeking ownership interests in businesses. The organization charged annual…
Determination 1338052: IRS denies exemption to an online aid platform that solicited funds for specific individuals
The IRS finalized an adverse determination for an organization that used an online platform to connect donors with people seeking financial assistance. The organization focused on Jewish applicants,…
Determination 1338051: IRS revokes exemption for an organization that did not operate as an insurance company
The IRS revoked an organization’s exemption under IRC § 501(c)(15) after concluding that it was not providing insurance to its policyholders. The organization had issued only two policies, did not…
Determination 1338050: IRS revokes social club exemption over private services for members’ homes
The IRS revoked a social club’s exemption under IRC § 501(c)(7). The club’s employees performed maintenance, repair, trash collection, and water services for members’ personally owned homes, and the…
Determination 1338049: IRS revokes exemption for an animal-rescue organization over private expenses and inadequate records
The IRS revoked an animal-rescue organization’s exemption under IRC § 501(c)(3). The organization rescued dogs and cats, placed them in foster homes, and charged adoption fees, but it could not…
Determination 1338048: IRS revokes veterans organization’s exemption over private inurement and unsupported activities
The IRS revoked a veterans organization’s exemption under IRC § 501(c)(19). The organization did not substantiate payments to its executive director and companies connected to him, including…
Determination 1338047: IRS revokes business league’s exemption over member-specific commercial services
The IRS revoked an organization’s exemption under IRC § 501(c)(6). The organization represented Hispanic publishers but had opened membership to many other businesses, professionals, and…
Determination 1338046: IRS revokes a small insurer's exemption after its premiums failed the 50 percent test
The IRS revoked an organization's exemption under IRC § 501(c)(15) for years beginning January 1, 20xx. The organization was formed to reinsure mechanical breakdown and guaranteed automotive…
Determination 1338045: IRS revokes title-holding company’s exemption for operating commercial facilities
The IRS revoked a title-holding company’s exemption under IRC § 501(c)(2). The company held property for a related tax-exempt organization but also controlled a bingo-hall concession stand, bar,…
Determination 1338044: IRS revokes social club’s exemption over non-member services
The IRS revoked an organization’s exemption under IRC § 501(c)(7). The organization was formed around property owners and provided services including snow removal, a summer shuttle, access to…
PLR 1338043: IRS permits a private foundation’s 35% holding limit after finding non-disqualified control
A private foundation asked whether non-disqualified persons effectively controlled a corporation in which the foundation and related persons held more than 20% but less than 35% of the voting stock.…
IRS determination revokes tax-exempt status for a horse-rescue organization
The IRS issued a final adverse determination concerning an organization formed to rescue and rehabilitate horses. It concluded that the organization had not shown that it operated exclusively for…
IRS revokes a social club’s tax-exempt status for public restaurant operations
The IRS revoked a social club’s exemption under IRC § 501(c)(7), effective January 1 of a redacted year. The club operated a restaurant, rented its banquet hall, and hosted events that were open to…
IRS revokes an organization's section 501(c)(3) exemption
The IRS issued a final adverse determination revoking an organization's federal income tax exemption under IRC § 501(c)(3), effective January 1, 2004. The IRS determined that the organization was…
IRS revokes a private foundation's section 501(c)(3) exemption
The IRS revoked a private foundation's recognition as an organization exempt under IRC § 501(c)(3), effective January 1 of the specified year. The final letter states that the organization was not…
IRS revokes an inactive organization's section 501(c)(3) exemption
The IRS revoked an inactive organization's recognition as exempt under IRC § 501(c)(3), effective January 1 of the specified year. The organization had stopped operating, reported that it intended…
IRS denies exemption for a public recreational gaming program
The IRS denied an organization's application for recognition as exempt under IRC § 501(c)(3). The organization offered free and low-cost tabletop gaming in a sober setting and said the programs…
IRS revokes a private foundation's exemption for private benefit to its founder
The IRS revoked a private foundation's section 501(c)(3) exemption effective November 1, 2008. The IRS found that a substantial amount of the organization's assets benefited its founder, including…
IRS approves an employer-related scholarship program
The IRS approved a private foundation's procedures for an employer-related scholarship program serving children of current full-time employees. The program uses an independent administrator and…
IRS approves a private foundation's transfer to a related charitable trust
The IRS approved a private foundation's proposed transfer of assets to a related private foundation organized as a charitable trust. The transfer was intended to resolve disagreements among family…
IRS reclassifies an organization from section 509(a)(1) to section 509(a)(2)
The IRS modified an organization's foundation classification from a publicly supported organization described under IRC §§ 509(a)(1) and 170(b)(1)(A)(vi) to one described under IRC § 509(a)(2). The…
IRS revokes a seafarer center's section 501(c)(4) exemption
The IRS revoked an organization's exemption under IRC § 501(c)(4), effective January 1 of the specified year. The organization operated a center serving crew members of cruise ships docking at a…
IRS revokes a charity's section 501(c)(3) exemption for lack of charitable activity
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective at its inception. The organization had not conducted activities related to its stated charitable purpose, had no assets…
IRS revokes a charity's section 501(c)(3) exemption for lack of charitable activity
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective September 21 of the specified year. The organization had not conducted activities related to its stated charitable…
IRS grants a private foundation more time to dispose of excess business holdings
The IRS granted a private foundation a five-year extension to dispose of stock that represented excess business holdings under IRC § 4943. The foundation received stock in eleven health care and…
IRS denies exemption to a farmers' market serving vendors' private interests
The IRS denied an organization's application for exemption under IRC § 501(c)(3) and, alternatively, § 501(c)(4). The organization operated a farmers' market where vendors paid fees for space and…
IRS denies exemption to a proposed rural hospital without sufficient operating details
The IRS denied a corporation's application for exemption under IRC § 501(c)(3) because it had not shown that it was operating or ready to operate a charitable hospital. The corporation planned to…
IRS denies exemption to a trust primarily supporting one named family
The IRS denied exemption under IRC § 501(c)(3) to a trust formed to support a widow and her children. The trust's original documents named that family as beneficiaries, its fundraising materials…
IRS revokes a small insurance company's section 501(c)(15) exemption
The IRS revoked an insurance company's exemption under IRC § 501(c)(15) because its gross receipts exceeded the applicable limitation for the year under examination. The organization had filed Form…
IRS approves a private foundation's hedge fund interests under UBTI, excess holdings, and jeopardizing investment rules
The IRS ruled on a private foundation's proposed ownership of interests in an investment hedge fund organized as an LLC. The Service concluded that income from the LLC's passive investment…
IRS revokes a social club's tax exemption after excessive nonmember income
The IRS revoked a social club's exemption under IRC § 501(c)(7). The organization received substantial income from nonmember use of its facilities and from oil, gas, and mineral royalties, and it…
IRS revokes a civic organization's exemption after finding extensive unrelated transportation businesses
The IRS revoked a transportation organization's exemption under IRC § 501(c)(4). The organization operated a city bus line that the examination report treated as an exempt activity, but it also…
IRS revokes an inactive civic organization's tax exemption
The IRS revoked a civic organization's exemption under IRC § 501(c)(4). The examination found that the organization had discontinued operations and therefore failed the operational test for…
IRS revokes a charity's exemption after it fails to provide examination records
The IRS revoked a charitable organization's exemption under IRC § 501(c)(3). The organization did not provide the records and other information repeatedly requested during an examination, so the IRS…
IRS revokes a charity's exemption for serving private rather than public interests
The IRS revoked a charitable organization's exemption under IRC § 501(c)(3). The organization did not provide books and records requested during an examination and acknowledged that it was not…
IRS denies exemption to a cannabis cooperative under IRC § 501(c)(16)
The IRS denied exemption to a proposed cooperative under IRC § 501(c)(16). The cooperative was not formed by a tax-exempt farmers' cooperative under IRC § 521, its corporate status had been…
1332015: IRS finalizes adverse determination for fraternal beneficiary society
The IRS finalized an adverse determination that an organization did not qualify for federal income tax exemption under IRC § 501(c)(8). The organization provided member benefits and raised money…
1332014: IRS proposes revoking a fraternal organization's tax exemption
The IRS determined that an organization did not qualify for exemption under IRC § 501(c)(8) as a fraternal beneficiary society. The organization rented halls and other facilities to the public, was…
1332013: IRS finalizes adverse determination for proposed Islamic educational broadcaster
The IRS finalized an adverse determination that an organization did not qualify for exemption under IRC § 501(c)(3). The organization proposed television programming, seminars, publications, and…
IRS revokes a foundation's tax exemption for serving private and commercial interests
The IRS revoked a foundation's recognition as a § 501(c)(3) organization effective January 1, 2006. The final adverse determination says the foundation operated in substantial part to promote a…
IRS revokes a family association's exemption for serving private interests
The IRS revoked a family association's recognition as a § 501(c)(3) organization. The association planned to manage and protect family land, sell timber, hold family reunions, and provide…
IRS denies social-welfare exemption to a fee-based project facilitator
The IRS denied a proposed § 501(c)(4) organization's application for exemption. The organization planned to identify sustainable development projects and connect them with a charitable funding…
IRS revokes an insurance company's § 501(c)(15) exemption after controlled-group receipts exceed the limit
The IRS revoked an insurance company's exemption under § 501(c)(15) after determining that the company's gross receipts had to include receipts from related companies under the controlled-group…
IRS finalizes adverse determination denying a group ruling for subordinates
The IRS finalized an adverse determination denying a parent organization’s request for a group ruling covering its subordinate organizations. The package explains that the subordinates’ activities…
IRS revokes exempt status after an organization fails to substantiate operations
The IRS revoked an organization’s recognition as exempt under § 501(c)(3), effective on the redacted date. The organization did not produce documents needed to establish that it operated exclusively…
IRS revokes an organization’s exempt status after it fails to file Form 990
The IRS revoked an organization’s recognition as exempt under § 501(c)(3), effective July 1 of the redacted year. The organization did not file its required Form 990 for a tax period ending June 30,…
IRS reclassifies a museum from section 509(a)(2) to section 509(a)(1)
The IRS changed a museum’s foundation classification from an organization described under § 509(a)(2) to one described under §§ 509(a)(1) and 170(b)(1)(A)(vi), effective January 1 of the redacted…
IRS denies exemption to a commercial consignment store that offered limited job training
The IRS denied an organization’s application for exemption under § 501(c)(3). The organization planned to operate a public consignment store and provide limited job training to people with special…
IRS denies exemption to a motorcycle-parts business controlled by related individuals
The IRS denied an organization’s application for exemption under § 501(c)(3). The organization planned to sell motorcycle parts and accessories through a website and use profits to support…
PLR 1329028 approves a private foundation's receipt of hedge-fund interests
The IRS rules that a private foundation's investment income from specified interests in a hedge-fund LLC will not be unrelated business taxable income under the stated facts. The IRS also concludes…
Determination 1329025 revokes a social club's section 501(c)(7) exemption
The IRS revoked a social club's exemption under IRC § 501(c)(7). The examination found that the club received substantial income from facility use by members of the general public and did not keep…
Determination 1329024 denies exemption to a shareholder-rights organization
The IRS denied exemption under IRC § 501(c)(6) to an organization formed to restore and maintain shareholder control over publicly traded corporations. Its members were individual and institutional…
Determination 1329023 revokes a real estate association's section 501(c)(6) exemption
The IRS revoked a real estate association's exemption under IRC § 501(c)(6). The association's primary activity was operating a multiple listing service for members, and the examination found that…
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.