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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Written determination 1245024: IRS revokes an inactive school's tax exemption
The IRS revoked a university preparatory school's exemption under section 501(c)(3), effective July 1 of a redacted year. The school had filed for bankruptcy, stopped conducting exempt activities,…
Written determination 1245023: IRS revokes an organization's tax exemption for missing records
The IRS revoked an organization's exemption under section 501(c)(3), effective July 1 of a redacted year. The organization did not provide all of the books, records, and other information needed to…
Written determination 1245022: IRS revokes an organization's exemption for inurement and missing records
The IRS revoked an organization's section 501(c)(3) exemption after finding that it paid personal expenses of its officers and did not keep adequate records to support the business purposes of its…
Written determination 1245021: IRS denies exemption for a commercial property arrangement
The IRS finalized its denial of exemption under section 501(c)(3) for a religious organization formed to own and lease a property used by other organizations. The organization conducted prayer…
Written determination 1244021: IRS denies tax exemption to a proposed nonprofit benefiting its founder and a for-profit company
The IRS denied a nonprofit corporation's application for recognition of tax exemption under IRC § 501(c)(3). The organization did not provide enough information about its proposed activities or its…
PLR 1244020: IRS approves a private foundation's asset transfers with conditions
The IRS ruled on a private foundation's proposal to transfer about two-thirds of its assets to two related private foundations. The IRS concluded that the transfers would qualify under IRC §…
PLR 1244005: IRS permits a homeowners association to revoke a section 528 election
A homeowners association filed Form 1120-H and elected the tax treatment provided by IRC § 528 without discussing the choice with its accounting firm. A new accounting firm later advised the…
PLR 1243015: IRS approves a private foundation's transfer of property to a related foundation
A private foundation planned to transfer real and personal property worth more than 25 percent of its assets to a related organization, Project, which was expected to qualify as a private operating…
IRS revokes an organization's section 501(c)(3) exemption after finding commercial activity and private inurement
The IRS issued a final adverse determination concluding that an organization did not qualify for exemption under IRC § 501(c)(3). The organization described housing, counseling, and other services,…
IRS denies section 501(c)(6) exemption to an association serving individual business interests
The IRS issued a final adverse determination denying exemption under IRC § 501(c)(6) to an association formed to serve health-care professionals. The association was controlled by one founder and…
IRS denies section 501(c)(3) exemption to a mentoring organization tied to a related LLC
The IRS issued a final adverse determination denying tax exemption under IRC § 501(c)(3) to a nonstock corporation formed to mentor underachieving students and provide related support services. The…
IRS denies section 501(c)(3) exemption to an Orthodox Jewish congregation
The IRS issued a final adverse determination denying tax exemption under IRC § 501(c)(3) to an Orthodox Jewish congregation that sought recognition as a church. The IRS found that the organization…
IRS revokes a social club's exemption because it lacked social activities and retained nonmember income
The IRS issued a final adverse determination revoking an organization's exemption under IRC § 501(c)(7). The organization held title to and maintained a building used by four fraternal…
IRS approves surrender of tax-exempt status by an electric cooperative
The IRS ruled that a mutual or cooperative electric company exempt under IRC § 501(c)(12) could surrender its tax-exempt status and operate as a taxable cooperative by filing a final Form 990…
IRS denies section 501(c)(3) exemption to a private family organization
The IRS denied exemption under IRC § 501(c)(3) to an organization that operated as a private family organization and sought recognition as a charitable organization. The IRS found that the…
IRS denies section 501(c)(3) exemption to an animal rescue organization
The IRS denied exemption under IRC § 501(c)(3) to an animal rescue organization that did not provide enough governing documents, activity details, or financial information to establish its exempt…
IRS revokes a nonprofit's section 501(c)(3) exemption for bingo operations
The IRS revoked a nonprofit organization's exemption under IRC § 501(c)(3) after finding that its primary activity was operating bingo games. The IRS concluded that the bingo activity was not an…
IRS denies unusual-grant treatment for a recurring donor's facility grant
The IRS considered a nonprofit animal clinic's request to treat a proposed grant from a longtime major donor as an unusual grant. The donor had founded the organization, contributed substantial…
IRS revokes a social club's exemption after public golf-course use and inadequate records
The IRS revoked a social club's tax exemption under IRC section 501(c)(7), effective January 1 of a redacted year. The club operated a golf course that was open to the public, charged nonmembers…
IRS revokes a women's networking organization's exemption for social activities and missing records
The IRS revoked an organization's exemption under IRC section 501(c)(3), effective January 1 of a redacted year. The organization described itself as a social networking forum for professional…
IRS revokes a community organization’s exemption after repeated failures to provide records
The IRS revoked a community organization’s exemption under IRC sections 501(a) and 501(c)(3), effective July 1 of a redacted year. The organization had suspended its activities after losing funding…
IRS revokes a country club’s exemption after public use exceeds the nonmember-income limit
The IRS revoked a country club’s exemption under IRC section 501(c)(7), effective October 1 of a redacted year. The club had opened its golf course, restaurant, bar, and other facilities to the…
IRS revokes a fraternal organization’s exemption after finding no exempt activities
The IRS revoked a fraternal organization’s exemption under IRC section 501(c)(10), effective January 1 of a redacted year. The organization had been created from a commercial bar business so the…
IRS revokes a scuba club’s exemption after nonmember trip income exceeds the limit
The IRS revoked a scuba-diving club’s exemption under IRC section 501(c)(7), effective January 1 of a redacted year. The club allowed nonmembers to attend its scuba trips and received nonmember…
PLR 1239012: IRS grants a nonprofit more time to revoke its lobbying election
An exempt public charity asked for more time to retroactively revoke its IRC § 501(h) lobbying election after becoming the sole member of an affiliated group. The organization said it had relied on…
IRS denies unusual-grant treatment for a recurring donor's facility grant
The IRS considered a nonprofit animal clinic's request to treat a proposed grant from a longtime major donor as an unusual grant. The donor had founded the organization, contributed substantial…
IRS revokes a veterans organization's section 501(c)(19) exemption
The IRS revoked a veterans organization's tax exemption under section 501(c)(19), effective on the stated date. The determination also revoked the organization's group exemption and said that its…
IRS denies business league exemption under section 501(c)(6)
The IRS denied tax-exempt status to an organization that planned to provide referrals and other services to businesses in a specialized industry. The organization’s founder also controlled a…
IRS revokes an organization's section 501(c)(3) exemption for bingo activity
The IRS revoked an organization’s section 501(c)(3) exemption effective on the stated date. The organization’s primary activity was conducting weekly bingo games and selling pull-tabs, while its…
IRS denies exemption to a job-training organization with commercial operations
The IRS denied section 501(c)(3) exemption to an organization that offered fee-based interview, career, coaching, and online training programs. The organization’s founders also controlled a…
IRS denies section 501(c)(3) exemption to a proposed religious sanctuary
The IRS denied tax-exempt status to an organization that planned to operate a religious sanctuary offering lodging, food, animal care, gardens, and produce sales. The organization did not describe…
PLR 1236032: Private foundation receives five more years to dispose of excess business holdings
The IRS granted a private foundation an additional five years to dispose of excess business holdings received through a QTIP trust. The foundation had sold most of the holdings but still owned a…
PLR 1235024: IRS approves tax treatment for a social club's conservation easement proceeds
The IRS ruled that a section 501(c)(7) social club's gain from selling a conservation easement would be exempt from tax under section 512(a)(3)(D) if the proceeds were reinvested in property used…
Final adverse determination: IRS denies exemption to an animal-rescue organization
The IRS finalized an adverse determination denying section 501(c)(3) exemption to an organization that rescued and sheltered abandoned dogs and cats. The organization lacked formal operating and…
Final adverse determination: IRS denies exemption to a claimed church
The IRS finalized an adverse determination denying section 501(c)(3) exemption to a small religious organization that claimed church status. The organization had fewer than 20 members, held most…
Final adverse determination: IRS denies exemption to an online giving foundation
The IRS finalized an adverse determination denying section 501(c)(3) exemption to a foundation that planned to collect donations online and remit them to selected charities. The foundation's…
Determination 1234030: IRS denies 501(c)(3) exemption to a foreclosure mortgage organization
The IRS denied tax-exempt status to an organization that planned to buy defaulted mortgages, restructure them, and foreclose on or sell homes when borrowers did not keep their homes. The…
Determination 1234029: IRS denies exemption to a conservation farm organization
The IRS denied tax-exempt status to an organization that planned to preserve farmland and protect wildlife while continuing to operate the property as a commercial hay farm. The organization’s…
Determination 1234028: IRS denies exemption to a private homeowners association
The IRS denied section 501(c)(4) exemption to a homeowners association that maintained parks, roads, and other facilities for subdivision property owners. Membership and park access were limited to…
IRS finalizes denial of exemption for an organization formed to fund a private business
The IRS finalized its adverse determination that an organization did not qualify for exemption under IRC § 501(c)(3). The organization was formed by the owners of a for-profit business and planned…
Other 1233017: IRS denies exemption to a proposed pharmaceutical manufacturer over commercial purpose and insider compensation
The IRS denied a proposed pharmaceutical manufacturer's application for exemption under IRC § 501(c)(3). The organization had not identified the drugs it would make, its manufacturing site, its…
IRS determination 1232036: final denial of tax-exempt status for an insurance administration organization
The IRS finalized its proposed adverse determination that an organization did not qualify for exemption under IRC § 501(c)(3). The organization provided third-party administration, insurance, and…
IRS determination 1232035: final denial of tax-exempt status for a credit counseling organization
The IRS finalized its proposed adverse determination that a credit counseling organization did not qualify for exemption under IRC § 501(c)(3). The organization offered debt management, credit…
IRS determination 1232034: final denial of church and tax-exempt status for an online ministry
The IRS finalized its proposed adverse determination that an online ministry did not qualify for exemption under IRC § 501(c)(3) or public charity treatment as a church. The organization offered…
IRS revokes an organization's exemption after repeated failures to provide information
The IRS revoked an organization's tax-exempt status under IRC §§ 501(a) and 501(c)(3), effective January 1 of a redacted year. The IRS stated that the organization did not establish that it…
PLR 1231015: Proposed division of a charitable lead trust will not trigger termination tax or excise taxes
A charitable lead unitrust asked whether it could divide its assets between two successor trusts with related charitable foundations as beneficiaries. The IRS ruled that the transfers would be…
PLR 1231014: Proposed division of a charitable lead trust will not trigger termination tax or excise taxes
A charitable lead unitrust asked whether it could divide its assets between two successor trusts while preserving the charitable and remainder interests described in its trust instrument. The IRS…
Written determination 1231013: IRS denies exemption to a single-brand franchisee association
The IRS issued a final adverse determination after a franchisee association did not protest a proposed adverse determination within 30 days. The association served franchisees of one restaurant…
Written determination 1231012: IRS denies exemption to a community wireless-network organization
The IRS issued a final adverse determination after a proposed denial of exemption was not protested within 30 days. The organization planned to provide free community Internet access through a…
PLR 1230026: IRS approves transfers of a private foundation's assets to two related foundations
A newly formed private foundation planned to transfer all of its assets to two other private foundations controlled by the same people, after receiving assets from a marital trust and charitable…
IRS denies exemption to a pain management clinic
The IRS issued a final adverse determination denying exemption under IRC § 501(c)(3) to a pain management clinic organized as a nonprofit corporation. The clinic charged patient fees for…
IRS denies exemption to a concession-staffing organization
The IRS issued a final adverse determination denying exemption under IRC § 501(c)(3) to an organization formed to raise money for youth and other charitable activities by staffing concession stands…
IRS denies § 501(c)(3) exemption to an organization formed to benefit a related business
The IRS issued a final adverse determination denying an organization exemption under IRC § 501(c)(3). The organization was formed primarily to obtain grant funding for a related for-profit company,…
IRS denies § 501(c)(3) exemption to a water-conservation organization linked to a for-profit publisher
The IRS issued a final adverse determination denying a water-conservation organization exemption under IRC § 501(c)(3). The organization shared board control with a related for-profit publisher…
IRS denies § 501(c)(3) exemption to a mortgage-foreclosure counseling organization
The IRS issued a final adverse determination denying a mortgage-foreclosure counseling organization exemption under IRC § 501(c)(3). The organization proposed counseling and possible mortgage…
Final adverse determination denying exemption for a grant-funded organization
The IRS issued a final adverse determination denying exemption under § 501(c)(3) to an organization formed to obtain grant funding for a related for-profit company. The organization's founders…
IRS denies exemption to a foreclosure counseling organization
The IRS finalized an adverse determination denying exemption under IRC § 501(c)(3) to an organization that provided or planned to provide legal and financial services to homeowners facing…
Determination 1225018: IRS revokes social club exemption after substantial nonmember activity
The IRS revoked a recreational organization's exemption under IRC § 501(c)(7). The organization operated a golf course, country club, swimming pools, tennis courts, clubhouse, restaurant, and…
Determination 1225017: IRS revokes charity exemption after operations cease
The IRS revoked a charitable organization's exemption under IRC § 501(c)(3), effective December 31 of the redacted year. The organization had stopped operating, had no planned operations or…
Determination 1225016: IRS revokes charity exemption for private benefit and inurement
The IRS revoked a charitable organization's exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization promoted American Indian culture and religion but the IRS…
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.