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 private foundation's section 501(c)(3) exemption for personal expenses and self-dealing
The IRS revoked a private foundation's section 501(c)(3) exemption retroactively to its formation. The foundation was created to make grants to other charitable organizations, but it made no such…
PLR 1309017: IRS approves a cooperative telephone company's discounted patronage-credit retirement program
The IRS considered a tax-exempt cooperative telephone company that wanted to retire members' and former members' patronage capital credits earlier than its usual cycle and pay their present value…
IRS denies section 501(c)(3) exemption to an advertising and fundraising website
The IRS denied exemption under section 501(c)(3) to an organization that planned to operate an advertising and fundraising website and offer nonprofit-management workshops. The Service concluded…
IRS revokes exemption from an organization that failed to establish medical research and made interest-free loans
The IRS revoked an organization’s section 501(c)(3) exemption because it did not establish that its current activity, transcribing decades of accumulated medical data, furthered an exempt purpose.…
Determination 1309014: IRS revokes a title-holding corporation's section 501(c)(2) exemption
The IRS revoked a title-holding corporation's exemption under IRC § 501(c)(2). The corporation had been formed to own an office building, lease it to a state agency, and use the lease payments to…
Other 1308032: IRS denies exemption to a foreclosure-counseling organization
The IRS issued a final adverse determination denying tax exemption under section 501(c)(3) to an organization that counseled homeowners about foreclosure and loan modifications. The IRS concluded…
IRS revokes section 501(c)(3) status for an organization operating a foreclosure counseling and loan program
The IRS revoked an organization's tax-exempt status under section 501(c)(3), effective January 1, 2008. The organization proposed foreclosure counseling, mortgage assistance, and no-interest loans,…
IRS denies section 501(c)(3) exemption to a foreclosure home purchase program
The IRS denied tax-exempt recognition to an organization that bought homes from homeowners facing foreclosure and resold them to the original owners through land sale contracts. The IRS concluded…
IRS denies exemption to an employment-services organization formed to pay its founder
The IRS denied exemption under section 501(c)(3) to an organization that planned to provide employment services to people with disabilities through a government referral and payment program. The IRS…
Determination 1306028: IRS revokes an organization’s section 501(c)(3) exemption for private benefit
The IRS revoked an organization’s federal income tax exemption under section 501(c)(3), effective January 1, 2006. The final adverse determination states that a substantial amount of the…
Determination 1306027: IRS revokes a social club’s section 501(c)(7) exemption over rental income
The IRS issued a final adverse determination that a social club did not qualify for exemption under section 501(c)(7). The club received a substantial portion of its income from renting part of its…
Determination 1306026: IRS denies section 501(c)(3) exemption for a commercial representative-payee operation
The IRS denied an organization’s application for exemption under section 501(c)(3). The organization proposed serving as a representative payee for government-benefit recipients and planned to…
PLR 1306023: IRS approves sale of long-held land interests without unrelated business income
The IRS considered a private operating foundation that owned land under condominium units and leased that land to unit owners. The foundation planned to sell its leased-fee interests gradually to…
IRS denies exemption to a mortgage-mitigation counseling organization
The IRS issued a final adverse determination denying an organization's application for recognition under IRC § 501(c)(3). The organization planned to provide mortgage-mitigation counseling and…
IRS denies exemption to a fee-based creditor-harassment service
The IRS issued a final adverse determination denying an organization's application for recognition under IRC § 501(c)(3). The organization charged fees to communicate with creditors on behalf of…
IRS denies exemption to a fee-based credit-repair organization
The IRS issued a final adverse determination denying an organization's application for recognition under IRC § 501(c)(3). The organization planned to repair clients' credit reports, charged setup…
IRS denies exemption to a farmer's market organization
The IRS denied tax-exempt status under IRC § 501(c)(3) to an organization that operated a weekly farmer's market. The organization described the market as a community gathering place and planned…
Determination 1303020: IRS denies exemption to a proposed government-services venture
The IRS denied exemption under IRC § 501(c)(3) to an organization that proposed researching government services, developing private-sector businesses from those services, and offering scholarships.…
Determination 1303019: IRS denies exemption to a fee-based credit counseling venture
The IRS denied exemption under IRC § 501(c)(3) to an organization that planned to market personal-finance education through financial professionals and distribute a related for-profit company's…
Determination 1303018: IRS denies exemption to an open-source music software organization
The IRS denied tax-exempt status under IRC § 501(c)(3) to a nonprofit corporation that planned to develop open-source software and provide online education for musicians and music companies. The…
Determination 1303017: IRS denies exemption to a charity funding a private farm
The IRS denied exemption under IRC § 501(c)(3) to a charity that funded projects connected to a farm owned by its director of operations and his family. The organization sent most of its…
IRS approves a social club's conservation-easement sale and reinvestment plan
A tax-exempt social and recreational club asked whether selling a conservation easement would affect its exemption and the tax treatment of reinvesting the proceeds. The IRS ruled that the one-time…
IRS denies section 501(c)(3) exemption to an organization with vague and commercial operations
The IRS finalized its denial of tax-exempt status to an organization that proposed health, fitness, education, and foreclosure-counseling activities. The organization did not provide enough…
IRS denies exemption to a foundation benefiting a related for-profit theater company
The IRS finalized its denial of exemption to a foundation formed by related individuals to support musical theater in a foreign country. The foundation's grants and financial support were…
IRS denies exemption to a foundation benefiting its founder and related businesses
The IRS denied recognition of tax-exempt status under IRC § 501(c)(3) to a foundation whose trustee and founder controlled or was connected to businesses receiving foundation funds. The…
PLR 1301014: IRS approves a financial education and savings program under section 501(q)
A public charity asked whether creating and operating a financial education, counseling, and savings program would affect its tax-exempt status. The program would provide financial literacy courses,…
IRS revokes a homeowners association's tax exemption
The IRS revoked a homeowners association's exemption under section 501(c)(4), effective on the stated date. The determination concluded that the organization did not serve a community within the…
IRS revokes a nonprofit's section 501(c)(3) exemption
The IRS revoked a nonprofit organization's exemption under section 501(c)(3), effective on the stated date. The determination found that the organization did not operate exclusively for exempt…
IRS revokes a veterans organization's section 501(c)(19) exemption
The IRS revoked a veterans organization's exemption under section 501(c)(19), effective on the stated date. The organization had eight active members and 51 members at large, and its primary…
IRS denies a financial literacy organization's section 501(c)(3) exemption
The IRS denied tax-exempt status to an organization that planned to provide financial literacy tools, services to low- and moderate-income households, and consulting services to small businesses.…
IRS denies a literary publisher's section 501(c)(3) exemption
The IRS denied tax-exempt status to an organization that planned to publish and promote literary works, including films, books, poetry, and music. The determination found that the activities were…
IRS denies a mixed-use community development organization's section 501(c)(3) exemption
The IRS denied tax-exempt status to an organization proposing mixed-use housing, community development, art museums, and educational and cultural programs. The organization did not have a valid…
IRS revokes an inactive organization's section 501(c)(3) exemption
The IRS revoked an organization's section 501(c)(3) exemption because it failed to provide information requested during an examination. The organization reported that it had been inactive and had…
IRS revokes a childcare organization's section 501(c)(3) exemption
The IRS revoked a childcare organization's section 501(c)(3) exemption because its actual operations differed materially from the information used to grant exemption. The organization accepted…
IRS revokes a psychologist's section 501(c)(3) exemption
The IRS revoked a psychologist's section 501(c)(3) exemption after finding that the organization operated in a commercial manner and did not provide evidence of charitable activity. The examination…
IRS revokes an organization's exemption and changes its foundation classification
The IRS revoked the organization’s section 501(c)(3) exemption because it did not provide the books and records needed to establish continued qualification. The examination also found that the…
IRS revoked an organization's § 501(c)(3) exemption for failure to substantiate operations
The IRS issued a final adverse determination revoking an organization's tax exemption under IRC § 501(c)(3), effective January 1, 2005. The organization did not provide enough information about its…
IRS denied exemption and church classification for an internet-based religious organization
The IRS issued a final adverse determination concluding that a religious organization did not qualify for exemption under IRC § 501(c)(3). The organization operated primarily through the internet,…
Determination 1250029: IRS denies exemption for a foreclosure-prevention organization
The IRS denied exemption under IRC section 501(c)(3) to an organization that proposed foreclosure-prevention counseling, mortgage-modification assistance, affordable-housing education, and related…
Determination 1250028: IRS denies exemption for a foreclosure class-action organization
The IRS denied exemption under IRC section 501(c)(3) to an organization that planned to raise donations from foreclosure victims and finance a nationwide class-action lawsuit. The organization…
Determination 1250027: IRS denies exemption for a foreclosure prevention organization
The IRS denied tax-exempt status under IRC section 501(c)(3) to an organization that proposed foreclosure prevention and mortgage counseling services. The organization charged clients upfront fees,…
PLR 1250025: IRS approves a health information exchange's related activities
The IRS ruled that a tax-exempt supporting organization could manage and facilitate a regional health information exchange and related performance-reporting program. The program combined health-plan…
PLR 1250024: IRS approves expanded membership for a voluntary employees' beneficiary association
The IRS ruled that a voluntary employees' beneficiary association (VEBA) could add common-law employees of Indian tribes, tribal organizations, and urban Indian organizations to its membership. The…
PLR 1250023: IRS approves expanded membership for a voluntary employees' beneficiary association
The IRS ruled that a voluntary employees' beneficiary association (VEBA) could add common-law employees of Indian tribes, tribal organizations, and urban Indian organizations to its membership. The…
PLR 1251019: Ticket revenue from a seasonal literacy event was not unrelated business income
The IRS ruled that ticket revenue from a nonprofit's seasonal event based on a literary work was not unrelated business taxable income. The organization used the event to promote reading, literacy,…
PLR 1251024: IRS allowed a VEBA to add certain Indian tribal organization employees
The IRS ruled that a tax-exempt voluntary employees' beneficiary association could add eligible employees of Indian tribes, tribal organizations, and urban Indian organizations to its membership.…
PLR 1251023: IRS allowed a VEBA to add certain Indian tribal organization employees
The IRS ruled that a tax-exempt voluntary employees' beneficiary association could add eligible employees of Indian tribes, tribal organizations, and urban Indian organizations to its membership.…
Determination 1249016: IRS denies exemption for a free investment advice organization
The IRS upheld a denial of tax-exempt status for an organization that planned to provide free investment advice and financial literacy assistance. The organization’s articles authorized purposes…
IRS revokes an organization's tax exemption after repeated failures to provide records
The IRS issued a final adverse determination revoking an organization's exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization did not provide records and other…
Written determination 1247019: IRS denies exemption to a local burial association
The IRS denied exemption under IRC § 501(c)(12) to a burial association serving members of an Ethiopian community in two states. The organization provided fixed funeral benefits funded by membership…
Written determination 1247018: IRS denies exemption to a proposed home tutoring organization
The IRS denied IRC § 501(c)(3) exemption to a proposed home-based tutoring organization. The organization was controlled by related directors, expected to serve only a few children, and planned for…
Written determination 1247017: IRS denies exemption to a fee-based grant-writing organization
The IRS denied IRC § 501(c)(3) exemption to a proposed organization that would provide grant-writing and notary services from its president's home. The organization planned to charge fees, advertise…
Written determination 1247016: IRS denies exemption to a proposed rural broadband network
The IRS denied IRC § 501(c)(3) exemption to a proposed organization that would build and operate an 800-mile fiber-optic broadband backbone in a rural area. The organization planned to lease network…
PLR 1246040: IRS confirms a church's parcels qualify for the neighborhood land rule
The IRS ruled that a church's three neighboring parcels would be treated as exempt from the debt-financed property rules under the neighborhood land rule. The church intended to demolish existing…
PLR 1246039: IRS confirms that state-funded member benefits do not create private inurement
The IRS ruled that a business league's use of state development-fund distributions to provide health and pension benefits would not create private inurement or adversely affect its § 501(c)(6)…
Written determination 1246038: IRS denies exemption to a mutual ditch and irrigation company support organization
The IRS denied exemption under IRC § 501(c)(12) to a nonprofit support organization for mutual ditch and irrigation companies. The organization held an annual workshop, published a newsletter, and…
Written determination 1246037: IRS revokes exemption from a purported integrated auxiliary
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 2006. The organization claimed to be an integrated auxiliary of a church, but the church did not know about or…
Written determination 1245027: IRS revokes an organization's tax exemption
The IRS revoked an organization's exemption under section 501(c)(3), effective January 1 of the redacted year. The organization operated an apartment complex and reported rental income as its only…
Written determination 1245026: IRS revokes a private foundation's tax exemption
The IRS revoked a private foundation's exemption under section 501(c)(3), effective January 1 of the redacted year. The foundation did not operate primarily for charitable or other exempt purposes,…
Written determination 1245025: IRS revokes a nonprofit organization's tax exemption
The IRS revoked a nonprofit organization's exemption under section 501(c)(3), effective January 1 of a redacted year. The organization raised money by working concession stands at sporting events…
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.