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 1329022: IRS revokes a homeowners association’s section 501(c)(4) exemption over private roads
The IRS revoked a homeowners association’s exemption under IRC § 501(c)(4). The organization maintained private roads and other property for owners, but its signs and access rules limited use of…
Determination 1329021: IRS denies exemption to an organization promoting an Internet identity standard
The IRS denied an organization’s application for exemption under IRC § 501(c)(3). The organization promoted a freely available Internet identity standard, developed the standard through volunteer…
Determination 1329020: IRS revokes an online university’s exemption for private inurement
The IRS revoked an online university’s exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The determination found that three officers benefited from repeated payments,…
Determination 1329019: IRS revokes a religious organization’s exemption over officer inurement and missing records
The IRS revoked a religious organization’s exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization spread Christian teachings through books, broadcasts, travel,…
Determination 1329018: IRS revokes arts organization’s exemption over gaming activity and missing returns
The IRS revoked an arts organization’s exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization’s primary activity was operating gaming programs, including instant…
PLR 1328035: IRS says an exempt organization’s S corporation ownership will not end its exemption
The IRS ruled that a tax-exempt supporting organization could own an interest in a for-profit S corporation through a wholly owned disregarded entity without losing its tax-exempt status. The S…
Other 1327019: IRS revokes an organization's tax-exempt status for commercial activity and private benefit
The IRS revoked an organization's section 501(c)(3) exemption after finding that it was not operated exclusively for exempt purposes. The organization collected donated books, but its activities and…
Other 1327018: IRS denies exemption to a proposed religious organization over private benefit and nonreligious activities
The IRS denied exemption under section 501(c)(3) to a proposed religious organization. The organization did not establish that its activities would be exclusively religious rather than social,…
Other 1327017: IRS revokes exemption after finding social and recreational purposes
The IRS revoked an organization's section 501(c)(3) exemption after finding that its articles of incorporation did not limit its purposes to exempt purposes. The IRS also found that more than an…
Other 1327016: IRS denies exemption to a social-welfare organization over private benefit and weak grant controls
The IRS denied exemption under section 501(c)(3) to an organization that proposed loans, grants, employment assistance, and related support for people facing financial hardship. The organization did…
Other 1327015: IRS proposes revocation after an inactive social-welfare group handled related clinic funds
The IRS proposed revoking an organization's exemption under IRC § 501(c)(4). The organization was inactive, while its bank account received credit card payments from clinics operated by a related…
Other 1327014: IRS denies exemption to an organic-certification organization serving private member interests
The IRS denied exemption to an organization that certified farms, processors, and traders using a trademarked organic-farming method. The organization argued that its certification, education, and…
Other 1327013: IRS revokes exemption after an organization remained inactive
The IRS revoked an organization’s exemption under section 501(c)(3) after finding that it had conducted no operations or financial activities during the examination year and several prior years. The…
Other 1327012: IRS revokes exemption after a housing organization ceased operations
The IRS revoked an organization’s exemption under section 501(c)(3) after finding that it had been inactive for several years and had no planned operations or financial activities. The organization…
Other 1327011: IRS revokes exemption after an organization withheld records
The IRS revoked an organization’s exemption under section 501(c)(3) after repeated unsuccessful efforts to examine its records, receipts, expenditures, and activities. The organization’s stated…
PLR 1327008: IRS permits a homeowners association to revoke section 528 elections
The IRS granted a homeowners association permission to revoke its elections under section 528 for two tax years. The association had filed Form 1120-H after an accounting firm advised that it could…
Other 1326019: IRS denies exemption to a foundation that made insider loans
The IRS denied section 501(c)(3) exemption to a foundation that made charitable grants and loans but also routed funds to related for-profit businesses. The foundation's directors and family members…
PLR 1325021: Early termination of a charitable remainder unitrust is approved
The IRS approved the early termination of a charitable remainder unitrust and the distribution of its assets. The income beneficiaries could receive the actuarial value of their interests, while the…
PLR 1325020: Early termination of a charitable remainder unitrust is approved
The IRS approved the early termination of a charitable remainder unitrust and the distribution of its assets. The income beneficiaries could receive the actuarial value of their interests, while the…
PLR 1325019: Early termination of a charitable remainder unitrust is approved
The IRS approved the early termination of a charitable remainder unitrust and the distribution of its assets. The income beneficiaries could receive the actuarial value of their interests, while the…
PLR 1325018: Early termination of a charitable remainder unitrust is approved
The IRS approved the early termination of a charitable remainder unitrust and the distribution of its assets. The income beneficiaries could receive the actuarial value of their interests, while the…
IRS denies exemption to a religious organization that could not substantiate its operations
The IRS finalized its adverse determination that a religious organization did not qualify for exemption under section 501(c)(3). The IRS found that the organization had not substantiated its…
Other 1325016: IRS denies exemption to a credit-counseling organization
The IRS denied exemption under section 501(c)(4) to an organization that offered debt analysis, credit counseling, and referrals to for-profit debt-service providers. The organization charged an…
Other 1325015: IRS denies exemption to a proposed church that promoted polygamy
The IRS denied section 501(c)(3) exemption to a proposed church whose trust instrument directed its assets on dissolution to an organization not shown to be tax exempt. The IRS also concluded that…
IRS determination 1324020: IRS denies section 501(c)(3) exemption to a rural broadband organization
The IRS issued a final adverse determination after an organization seeking section 501(c)(3) status did not protest a proposed denial within 30 days. The organization said it would represent rural…
Determination 1323039: IRS revokes exemption after private benefit and inurement findings
The IRS revoked an organization’s exemption under IRC § 501(c)(3) after finding that its partnership and donor program provided private benefits and inurement. The organization allowed donors to…
Determination 1323038: IRS revokes a veterans organization’s section 501(c)(4) exemption
The IRS revoked a central organization’s section 501(c)(4) exemption and its related group exemption. The organization provided administrative services to subordinate organizations that operated…
Determination 1323037: IRS finalizes denial of exemption for a fee-based charity website
The IRS issued a final adverse determination that an organization did not qualify for exemption under IRC § 501(c)(3). The organization operated a website connecting people who offered goods or…
Determination 1323036: IRS revokes exemption from a public-facing employee association store
The IRS revoked an employee association's exemption under IRC § 501(c)(4). The association operated a public-facing store selling public safety apparel and equipment, and the IRS found that store…
IRS denies exemption after finding private benefit and inurement
The IRS determined that a nonprofit did not qualify for exemption under section 501(c)(3), effective September 19, 2007. The organization’s founder controlled its finances and used personal credit…
IRS revokes exemption after finding commercial activity and officer inurement
The IRS revoked an organization’s section 501(c)(3) exemption, effective January 1, 2007. The examination found that the organization’s primary activity was providing immigration services for fees…
IRS revokes a social club's exemption after it ceases operations
The IRS revoked a social club’s exemption under section 501(c)(7), effective July 1 of the redacted year. The organization had ceased active operations, did not provide requested books and records,…
IRS revokes a civic organization's exemption after it operated a public bar
The IRS revoked an organization's tax exemption under section 501(c)(4). The organization operated a bar for its members and the general public, and the IRS concluded that this activity was not…
IRS revokes a dissolved organization's tax exemption
The IRS revoked an organization's exemption under section 501(c)(4), effective on a redacted date. The organization told the IRS that its exemption did not meet its purposes, stopped doing business,…
IRS revokes an organization's exemption after missed reporting
The IRS revoked an organization's tax-exempt status after it failed to file required Forms 990 for two tax periods and did not timely respond to IRS requests for the information. The examination…
PLR 1323029: Foundation's art subsidiary is functionally related and its management fees are not UBTI
The IRS considered a private foundation's plan to receive all stock of a corporation holding an artist's collection and copyrights. The foundation planned to use those assets for exhibitions,…
IRS denies exemption for fee-based credit-repair activities
The IRS denied an organization's application for recognition under section 501(c)(3). The organization proposed credit counseling, credit education, budget education, and a fee-based do-it-yourself…
IRS revokes a section 501(c)(4) organization's exemption for missing records
The IRS revoked a section 501(c)(4) organization's exemption after the organization failed to provide records needed to examine its Forms 990 and failed to meet reporting requirements under sections…
IRS revokes a section 501(c)(4) organization's exemption for nonresponse
The IRS revoked a section 501(c)(4) organization's exemption after it failed to respond to repeated requests for records and failed to file required Forms 990 for a tax period ending June 30 of a…
IRS denies exemption to organization advocating for polygamy-related legal change
The IRS denied an organization's application for section 501(c)(3) exemption. The organization described its work as educational, charitable, and supportive of a polygamous community, including…
IRS denies exemption to donor-fund organization tied to a for-profit platform
The IRS denied an organization's application for section 501(c)(3) exemption. The organization proposed receiving donations, allowing donors to identify charitable causes, and distributing funds to…
Other 1322054: IRS revokes a charity's exemption over commercial operations and private benefit
The IRS revoked a charitable organization's exemption under section 501(c)(3), effective on the date stated in the final determination. The release says the organization operated primarily through…
Other 1322053: IRS denies exemption to a commercial truck-and-tractor-pull organization
The IRS denied section 501(c)(3) exemption to an organization formed around an annual truck-and-tractor-pull event. The release says the event was the organization's primary activity, with revenue…
IRS revokes an organization's section 501(c)(3) exemption for operating as a social club
The IRS revoked an organization's recognition as a section 501(c)(3) public charity. The organization primarily operated recreational facilities, a function hall, a bar, and related services for…
IRS revokes a social club's section 501(c)(7) exemption for excess nonmember income
The IRS revoked a social club's exemption under section 501(c)(7). The club operated a clubhouse, golf course, and recreation facilities for members and the general public, while membership declined…
IRS retroactively revokes an organization's section 501(c)(3) exemption for unsupported foreign activities
The IRS revoked an organization's section 501(c)(3) exemption, effective from the redacted date on which it was founded. The organization said it trained volunteers and helped children abroad, but…
IRS denies exemption to an organization proposing foreign surveillance and housing programs
The IRS denied section 501(c)(3) exemption to an organization proposing foreign surveillance, communications, and housing projects. The organization could not show that it controlled funds sent to…
Determination 1321041: IRS denies section 501(c)(3) exemption for private benefit and inurement
The IRS issued a final adverse determination against an organization involved in debt-management services. It concluded that the organization did not operate exclusively for exempt purposes, served…
Determination 1321040: IRS revokes exemption after recordkeeping and private-benefit failures
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 2007. The determination says the organization did not meet the recordkeeping requirements of IRC § 6033 and…
IRS revokes a homeowners association's section 501(c)(4) exemption
The IRS revoked a homeowners association's exemption under section 501(c)(4). The association maintained a swimming pool, roads, security lights, trees, and other common areas, but those facilities…
IRS revokes an organization's exemption after it failed to respond to an examination
The IRS revoked an organization's exemption under section 501(c)(4). The organization failed to file required Form 990 returns and did not respond to repeated IRS requests for records and…
IRS revokes a social-welfare organization's exemption after it ceased its activities
The IRS revoked an organization's exemption under section 501(c)(4). The organization had been engaged in activities intended to promote social welfare, including advocacy concerning the quality of…
IRS revokes an employee association's exemption for substantial commercial insurance activity
The IRS revoked a local employee association's section 501(c)(4) exemption. The association provided commercial-type insurance to its members, and the IRS determined that this was a substantial part…
IRS revokes a homeowners association's exemption because its common areas served members
The IRS revoked a homeowners association's exemption under section 501(c)(4). The association maintained an office building, swimming pool, play areas, a dumpster, utility meters, and roads, but…
IRS revokes exemption from organization whose only activity was gaming
The IRS revoked an organization's exemption under IRC § 501(c)(4), effective January 1 of the redacted year. The organization had originally been formed to support a youth football league, but it…
IRS revokes exemption from homeowners association with member-only facilities
The IRS revoked an organization's exemption under IRC § 501(c)(4), effective January 1 of the redacted year. The organization administered covenants, maintained common property, and operated a…
Final adverse determination: IRS denies business-league exemption for an identity-theft services organization
The IRS issued a final adverse determination denying federal income tax exemption under IRC § 501(c)(6) to an organization formed by nonprofit groups representing financial-services companies. The…
PLR 1321025: IRS approves a private foundation's asset transfer, termination plan, and related tax treatment
A private non-operating foundation planned to transfer substantially all of its remaining assets to a related private operating foundation controlled by the same people. The IRS ruled that the…
PLR 1321024: IRS approves a private foundation's asset transfer, termination plan, and related tax treatment
A private non-operating foundation planned to transfer substantially all of its remaining assets to a related private operating foundation controlled by the same people. The IRS ruled that the…
TAM 1320023: Insurance sales to non-member widows are unrelated business
The IRS considered whether a fraternal beneficiary society's sales of life insurance to widows of deceased insured members were substantially related to its exempt purposes. The widows were not…
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.