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 1319031: IRS denies exemption to a member-benefit association
The IRS finalized its denial of exemption under IRC § 501(c)(4) for a membership association that offered members limited medical indemnity benefits, discounts, health information, and scholarships.…
IRS proposed revocation for failure to file required returns
The IRS proposed revoking a social welfare organization's tax-exempt status because it failed to file required Form 990 returns and did not provide the requested records or responses. The…
Other 1318027: IRS revokes a dog club's tax-exempt status
The IRS revoked a dog club's exemption under section 501(c)(3). The organization conducted dog shows, obedience training, and related matches, and it argued that these activities educated dog owners…
Other 1318026: IRS revokes a social club's tax-exempt status
The IRS revoked a social club's exemption under section 501(c)(7). The club promoted clay target shooting, conducted shooting events, and admitted special or daily members who were treated as…
Other 1318025: IRS revokes an organization's tax exemption for filing failures
The IRS proposed revoking an organization's exemption under section 501(c)(4) because it did not respond to IRS correspondence or file required Forms 990 for the relevant tax periods. The…
Other 1318024: IRS proposes revoking a neighborhood organization's exemption
The IRS proposed revoking a neighborhood organization's exemption under section 501(c)(4). The organization provided newsletters, directories, community events, and a security patrol for…
Other 1318023: IRS revokes a private residential association's exemption
The IRS revoked a residential association's exemption under section 501(c)(4). The association maintained private roads and common areas, provided security patrols, and served a restricted…
Other 1318022: IRS revokes a private homeowners association's exemption
The IRS revoked a homeowners association's exemption under section 501(c)(4). The association maintained private common areas, including a swimming pool, play areas, roads, and other facilities, and…
Other 1318021: IRS revokes a members-only organization's exemption
The IRS revoked a members-only organization's exemption under section 501(c)(4). The organization operated a bar and function hall, provided member benefits, and donated some income to local schools…
Other 1318020: IRS revokes a neighborhood patrol association's exemption
The IRS revoked a neighborhood patrol association's exemption under section 501(c)(4). The association hired off-duty police officers to patrol a residential subdivision, provided emergency contact…
Other 1318019: IRS revokes a dormant group's exemption for filing failures
The IRS revoked a subordinate organization's exemption under section 501(c)(4). The organization had ceased operations, had no financial resources or assets, and failed to file required returns and…
Other 1318018: IRS revokes an inactive organization's exemption
The IRS revoked an organization's exemption under section 501(c)(4) because it had stopped operating. During the examination, a representative said that the organization no longer conducted…
Other 1318017: IRS proposes revoking an agricultural and equestrian facility's exemption
The IRS proposed revoking an organization's exemption under section 501(c)(3). The organization planned to own and operate facilities for agricultural, equestrian, and other public events, but later…
Other 1318016: 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 restricted access to its common areas to members and guests, and used police assistance, gates, keys,…
Other 1318015: IRS proposes revoking a volunteer fire organization’s exemption
The IRS proposed revoking an organization’s exemption under section 501(c)(4). The organization was formed to provide volunteer fire and emergency services, but the IRS found almost no documented…
Other 1318014: IRS revokes a credit-counseling organization’s exemption
The IRS revoked a credit-counseling organization’s exemption under section 501(c)(4), effective January 1, 20XX. The organization initially proposed debt-management and counseling services for needy…
Other 1318013: IRS revokes a private golf and country club’s exemption
The IRS revoked a private golf and country club’s exemption under section 501(c)(4), retroactive to January 1, 20XX. The organization operated a public golf course alongside member facilities, but…
Other 1318012: IRS revokes a homeowners association’s section 501(c)(3) exemption
The IRS revoked a homeowners association’s exemption under section 501(c)(3), effective January 1, 20XX. The organization had originally been treated as a municipal corporation, but after the…
Other 1318011: IRS revokes exemption for failure to file returns and maintain records
The IRS revoked an organization’s exemption under section 501(c)(4), effective January 1, 20XX. The organization failed to respond to IRS correspondence, file required Form 990 returns, and maintain…
Other 1318010: IRS revokes section 501(c)(4) status but finds section 501(c)(7) qualification
The IRS revoked the organization’s exemption under section 501(c)(4), effective January 1, 20XX. The organization hosted social events for residents of a residential tower complex, but did not…
Other 1318009: IRS revokes an organization’s tax-exempt status
The IRS revoked the organization’s exemption from federal income tax under section 501(c)(3), effective January 1, 20XX. The letter says the organization operated for a substantial non-exempt…
IRS 1317020: Exempt status revoked after organization failed to provide records
The IRS issued a final adverse determination revoking an organization's section 501(c)(3) exemption effective January 1 of the redacted year. The IRS stated that the organization had not established…
PLR 1317017: IRS distinguishes reporting rules for IRA and 529 account bonuses
The IRS ruled on the information-reporting treatment of bonuses a financial-services group planned to pay when clients opened and funded IRA or section 529 accounts. Bonuses credited to an IRA were…
IRS revokes a social club's section 501(c)(7) exemption
The IRS revoked a social club's exemption under IRC section 501(c)(7). The club operated shooting ranges, a fishing pond, a clubhouse, and related recreational facilities, and opened many of those…
IRS revokes a dog club's section 501(c)(7) exemption
The IRS revoked a dog club's exemption under IRC section 501(c)(7). The organization held dog shows, obedience trials, sanctioned matches, and other activities in which the general public regularly…
IRS revokes a campground social club's section 501(c)(7) exemption
The IRS proposed revoking a campground social club's exemption under IRC section 501(c)(7). The organization had sold its assets to pay liabilities, distributed the remaining funds to members, and…
PLR 1317013: IRS finds preferential cleanup payments jeopardize section 501(c)(4) status
The IRS ruled against a section 501(c)(4) environmental cleanup organization that proposed reducing a member's cleanup-related liability through a special fund and reimbursement agreement. The…
IRS denies section 501(c)(3) recognition after applicant fails to substantiate operations
The IRS denied an organization's application for recognition under IRC section 501(c)(3). The applicant described drug-rehabilitation, counseling, religious, and outreach activities, but did not…
IRS denies section 501(c)(3) recognition to a fee-based charity investment fund
The IRS finalized its denial of section 501(c)(3) recognition for a foreign common investment fund serving registered charities. The fund’s governing declaration did not expressly limit its purposes…
Determination 1315037: IRS revokes a feline organization’s tax exemption for private benefit and inadequate records
The IRS revoked a feline organization's section 501(c)(3) tax exemption, effective January 1, 2007. The organization educated the public about feline retroviruses and sheltered infected cats, but…
PLR 1315030: IRS approves a tax-exempt country club's liquidation of its property subsidiary
A tax-exempt country club asked whether it could completely liquidate its tax-exempt subsidiary and receive the subsidiary's assets and liabilities without recognizing gain or loss. The subsidiary…
Determination 1315029 denies exemption to a video-education organization
The IRS issued a final adverse determination denying exemption under IRC § 501(c)(3) to an organization that edited, packaged, and sold educational video books. The organization did not have a…
Determination 1315028 denies exemption to a medical-practice network
The IRS issued a final adverse determination denying exemption under IRC § 501(c)(3) to a nonprofit medical-practice network. The organization planned to collect and analyze practice data, provide…
Determination 1315027 denies exemption to an administrative-services organization
The IRS denied exemption under IRC § 501(c)(3) to an organization formed to provide management, human resources, finance, health-record, information-technology, property, transportation, and…
Determination 1314058: IRS revokes exemption for organization operating commercial debt programs
The IRS issued a final adverse determination revoking an organization's section 501(c)(3) tax-exempt status. The examination found that the organization operated primarily through debt management,…
Determination 1314049: IRS denies exemption to a proposed mortgage foreclosure counseling organization
The IRS denied exemption to a proposed organization that planned to provide mortgage foreclosure counseling, loss mitigation, housing and financial education, and other aid programs. The…
Determination 1314048: IRS denies exemption to a fee-based credit restoration organization
The IRS denied tax-exempt status to a nonprofit that planned to provide credit restoration, identity theft protection, credit education, and related services. The organization charged membership and…
Determination 1314047: IRS denies exemption to an equine-therapy organization linked to a for-profit riding business
The IRS denied exemption to an organization that planned to provide equine therapy, riding clinics, and related training. Its founder also owned a for-profit business that offered similar riding…
Determination 1314045: IRS denies exemption to a mortgage counseling organization
The IRS denied exemption to an organization that planned to counsel homeowners facing mortgage problems, help with loan modifications, and provide housing and financial education. It did not limit…
PLR 1314044: IRS approves a hospital system's revised governance structure
A tax-exempt hospital asked whether it would remain exempt and classified as a public charity after changing how its board related to the board of its parent healthcare system. The hospital would…
IRS denies exempt status to a restaurant-operated social organization
The IRS Appeals Office issued a final adverse determination for an organization that claimed exemption under sections 501(c)(7) and 501(c)(4). The organization primarily operated a restaurant and…
IRS revokes a foundation's tax-exempt status over private benefit and donor-advised fund operations
The IRS issued a final adverse determination revoking an organization's section 501(c)(3) exemption effective on the stated date. The IRS concluded that the organization primarily administered a…
IRS denies exemption to a founder-owned minor-league football organization
The IRS issued a final adverse determination to a minor-league football organization that sought recognition under section 501(c)(3). The organization was formed from a prior for-profit team,…
IRS denies exemption to a founder-controlled medical-device research organization
The IRS issued a final adverse determination to an organization formed to research and commercialize a medical diagnostic device. The organization was controlled by the founder and the founder's…
IRS revokes a gated homeowners association's section 501(c)(4) exemption
The IRS revoked a homeowners association's section 501(c)(4) exemption effective on the stated date. The association maintained private roads and common areas for a gated residential development,…
PLR 1311036: IRS rules that endowment units do not generate UBTI
The IRS ruled that a charitable remainder trust’s proposed contractual units in an educational organization’s endowment would not generate unrelated business taxable income. The units would provide…
IRS finalizes denial of tax-exempt status for a financial education organization
The IRS finalized its proposed adverse determination that an organization did not qualify for exemption under IRC § 501(c)(3). The organization planned to provide financial education and financial…
IRS determination 1311032: IRS rules that contractual endowment units do not generate UBTI
The IRS ruled that a charitable remainder trust’s proposed contractual units in an educational organization’s endowment would not generate unrelated business taxable income. The units would give the…
IRS determination 1311031: IRS approves expanded training and advertising activities for a labor organization
The IRS ruled that a training trust exempt as a labor organization could amend its governing document to add safety training, professional development, and advertising and marketing activities. The…
Determination 1311030: IRS denies section 501(c)(3) exemption to a scientific organization
The IRS denied exemption to an organization formed to research, develop, and commercialize a medical-detection device. The organization planned to market devices and license results, while its…
IRS determination 1311029: IRS finalizes denial of exemption for a mortgage counseling organization
The IRS finalized its adverse determination that a mortgage counseling organization did not qualify for exemption under IRC § 501(c)(3). The organization’s activities included mortgage mitigation…
IRS determination 1311028: IRS finalizes denial of exemption for an organization with insufficiently described operations
The IRS finalized its adverse determination that an organization did not qualify for exemption under IRC § 501(c)(3). The IRS said the organization had not described its operations in enough detail…
IRS denies tax exemption to a housing and foreclosure assistance organization
The IRS issued a final adverse determination denying an organization recognition as exempt under IRC § 501(c)(3). The organization offered housing counseling, foreclosure assistance, grants,…
IRS denies tax exemption to an organization serving marriage and financial counseling programs
The IRS issued a final adverse determination denying an organization recognition as exempt under IRC § 501(c)(3). The organization offered conferences and counseling about marriage, biblical…
IRS denies exemption to a religious trust that promoted polygamy
The IRS issued a final adverse determination denying a religious trust exemption under IRC § 501(d). The trust maintained a common treasury, operated businesses for the community, and required…
IRS denies exemption to a fundraising organization operating a coffee and hot chocolate business
The IRS issued a final adverse determination denying an organization exemption under IRC § 501(c)(3). The organization purchased packaged coffee and hot chocolate and resold the products through…
IRS written determination 1310045: IRS denies exemption and church classification to a religious organization
The IRS issued a final adverse determination after a religious organization did not protest a proposed denial within 30 days. The organization described a ministry division, an affiliated church, an…
PLR 1310043: IRS gives mixed information-reporting answers for IRA and section 529 bonuses
A financial-services group asked how to report bonus payments credited under an IRA promotion and a section 529 promotion. The IRS ruled that the IRA bonus payments were not subject to information…
Other 1309029: IRS denies exemption to an organization serving related for-profit entities
The IRS denied an organization's application for exemption under section 501(c)(3). The organization initially provided automotive training under contracts with for-profit companies, later…
IRS denies section 501(c)(3) exemption to a mortgage-assistance and credit-counseling organization
The IRS denied federal income tax exemption under section 501(c)(3) to a nonprofit organization that planned to provide mortgage and financial assistance, credit counseling, and other charitable…
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.