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 denies section 501(c)(3) exemption to a health care information organization
The IRS denied tax-exempt status under section 501(c)(3) to an organization that proposed health care information, report-card, wellness, electronic-record, and consulting activities. The…
PLR 1216045: IRS approves variable ascending payments from a charitable lead annuity trust
An irrevocable testamentary charitable lead annuity trust asked whether a state-court construction of its trust agreement could permit annuity payments to rise each year over a 10-year term. The IRS…
Determination 1216040: IRS denies exemption to a health-information technology organization
The IRS issued a final adverse determination denying an organization's application for exemption under IRC § 501(c)(3). The organization planned to implement a health-information exchange and…
IRS denies exemption to a fertility pharmacy operated in a commercial manner
The IRS considered an organization's request for recognition as a section 501(c)(4) social welfare organization. The organization operated a pharmacy that sold fertility medication, sometimes at…
IRS denies exemption to a homeowners advocacy association
The IRS finalized an adverse determination for a homeowners advocacy association that sought exemption under IRC §§ 501(c)(6) and 501(c)(4). The association represented property owners in a private…
IRS denies exemption to a housing and financial-literacy organization
The IRS denied an organization's request for recognition under IRC § 501(c)(3). The organization proposed affordable housing services, foreclosure assistance, financial-literacy programs, home…
IRS denies exemption to a free credit-repair organization
The IRS denied an organization's request for recognition under IRC § 501(c)(3). The organization offered free credit repair and planned to seek donations and grants, but its sole substantive…
IRS denies exemption to a fundraising organization supporting a foreign research project
The IRS denied a U.S. organization's application for recognition under IRC § 501(c)(3). The organization raised funds for a foreign organization and said its money supported rabbis researching and…
IRS denies exemption to a stock-trading charity
The IRS denied an organization's application for recognition under IRC § 501(c)(3). The organization planned to buy and sell stocks and options with donated funds, retain some proceeds, and give a…
IRS denies exemption to a political campaign support organization
The IRS denied a political organization's application for exemption under IRC section 501(c)(4). The organization planned to devote 80 percent of its activities to supporting a political candidate,…
IRS approves a central-counterparty structure for a regional transmission organization
The IRS ruled that a regional transmission organization’s plan to become the central counterparty for transactions in the electricity markets it administers would not affect its section 501(c)(3)…
PLR 1214016: IRS grants more time for one homeowners association election year
The IRS considered a homeowners association's request to make late elections under IRC § 528 for two taxable years. The association had filed Forms 1120 instead of Forms 1120-H after relying on an…
PLR 1213035: IRS revokes prior ruling on gain from a social club's property sale
The IRS revoked and superseded a 2003 ruling for a section 501(c)(7) club that planned to dissolve and sell land used in its exempt activities. The earlier ruling had concluded that the sale would…
PLR 1213034: IRS revokes prior ruling on gain from a boating club's property sale
The IRS revoked and superseded a 2004 ruling for a section 501(c)(7) boating club that planned to sell and liquidate its assets. The earlier ruling had concluded that gain from the sale would not be…
IRS denies section 501(c)(7) exemption to a property-rights club
The IRS finalized its denial of section 501(c)(7) exemption to a club formed by cabin owners and their supporters. The club's main activity was pooling member resources to litigate individual…
IRS denies exemption under sections 501(c)(4) and 501(c)(6) to a trade-services organization
The IRS finalized its denial of exemption under sections 501(c)(6) and 501(c)(4) to an organization that promoted trade, investment, and business opportunities for selected small and medium-sized…
IRS denies section 501(c)(3) exemption to a mortgage counseling organization
The IRS denied section 501(c)(3) exemption to an organization providing mortgage mitigation and credit counseling services. The organization charged fees, shared operations and personnel with a…
IRS denies section 501(c)(3) exemption to a mortgage assistance foundation
The IRS denied section 501(c)(3) exemption to an organization that helped homeowners refinance mortgages and paid related costs. The organization also performed paid research for a for-profit…
PLR 1213029: Central counterparty structure does not affect exemption or create unrelated business income
The IRS considered whether an independent system operator's planned central-counterparty structure would affect its section 501(c)(3) exemption. The operator would briefly take title to electricity…
Written determination 1210044: Solar energy program denied 501(c)(3) exemption
The IRS denied tax-exempt status to an organization that planned to provide residential solar energy systems to low and moderate income households. The organization said its program would alleviate…
Written determination 1210043: Cooperative art gallery denied 501(c)(3) exemption
The IRS denied exemption to a cooperative art gallery formed by local artists to display and sell their work. The gallery also offered workshops, but the IRS found that selling members' artwork was…
Written determination 1210042: Constitution study-club program denied 501(c)(3) exemption
The IRS denied exemption to an organization that planned to provide constitutional study materials to independently formed clubs. The organization’s executive director owned the related for-profit…
Written determination 1210041: Medical office and related nonprofit denied 501(c)(3) exemption
The IRS denied exemption to a proposed nonprofit that would operate a low-cost medical office alongside a related for-profit practice. The same doctor would control both operations, provide the…
PLR 1210007: Homeowners association receives more time to elect § 528 treatment
The IRS granted a homeowners association 120 days to file Forms 1120-H and make its election to be treated under IRC § 528 for two taxable years. The association had relied on an independent CPA…
PLR 1208038: Endowment fund units do not create UBTI and are capital assets
The IRS considered a charitable organization that served as trustee and charitable remainder beneficiary of a charitable remainder unitrust. The organization proposed to invest the trust's assets in…
PLR 1206018: Church land qualifies for the 15-year neighborhood land exception
A church bought land with borrowed funds to build a larger campus. It demolished the existing buildings, built and occupied a new worship center and related facilities, and continued to hold some…
Determination 1205015: IRS denies exemption to a local farmers market organization
The IRS finalized its denial of tax-exempt status to an organization that operated a local farmers market and related educational programs. The organization argued that it served local growers and…
Determination 1205014: IRS denies exemption to a farmers market organization
The IRS finalized its denial of tax-exempt status to an organization that operated a farmers market with educational activities, food-bank donations, and community programming. The organization…
Determination 1205013: IRS denies exemption to a religious product distributor
The IRS finalized its denial of tax-exempt status to an organization that sold religious books, music, DVDs, and related materials through churches and religious bookstores. The organization argued…
Determination 1205012: IRS denies exemption to a foreclosure counseling organization
The IRS finalized its denial of exemption to an organization that sold access to web-based loan-modification software and provided related counseling and technical support. The organization…
Determination 1205011: IRS denies exemption to a family-centered disability services organization
The IRS finalized its denial of exemption to an organization formed to support three children of one family with home and community services for developmental disabilities. The organization planned…
Determination 1205010: IRS denies exemption to a harvest-financing organization linked to a for-profit supplier
The IRS denied exemption to an organization that planned to finance farmers and growers in developing countries and support food safety, school, and nutrition programs. The organization was…
Determination 1204021: IRS denies exemption to a commercial publishing organization
The IRS issued a final adverse determination that a publishing organization did not qualify for tax exemption under IRC § 501(c)(3). The organization published and marketed Christian books, sold…
Determination 1204020: IRS denies exemption to a neighborhood recreation organization
The IRS issued a final adverse determination that a neighborhood organization did not qualify for exemption under IRC § 501(c)(3). The organization held block parties, boat parades, volleyball…
Determination 1204019: IRS denies exemption to a grant-funded nonprofit tied to a for-profit business
The IRS issued a final adverse determination that a nonprofit corporation did not qualify for exemption under IRC § 501(c)(3). The corporation was formed after promoters offered grants that would…
Determination 1204018: IRS denies exemption to a social club operating a public restaurant
The IRS issued a final adverse determination that a social club did not qualify for exemption under IRC § 501(c)(7), and the proposed determination also rejected exemption under § 501(c)(4). The…
Determination 1204017: IRS denies exemption to a condominium association
The IRS issued a final adverse determination that a 12-unit condominium association did not qualify for exemption under IRC § 501(c)(4). The association maintained roofs, buildings, driveways,…
PLR 1204016: Mission society does not qualify for an exception from Form 990 filing
The IRS denied an organization's request to be excepted from filing Form 990 as a mission society. The organization provided humanitarian aid abroad, satisfying the foreign-activity part of the…
IRS revokes an organization's section 501(c)(3) exemption for nonexempt activity and private inurement
The IRS revoked an organization's federal tax exemption under section 501(c)(3), effective on the redacted date stated in the letter. The IRS concluded that the organization was not operated…
IRS revokes a section 501(c)(3) exemption for private inurement and nonexempt activity
The IRS revoked an organization's federal tax exemption under section 501(c)(3), effective January 1, 2007. The examination report states that the organization commingled its bank account with the…
IRS revokes a section 501(c)(3) exemption for private inurement and personal activity
The IRS revoked an organization's federal tax exemption under section 501(c)(3), effective on the redacted date stated in the letter. The examination report states that the organization held…
IRS determination 1203025: IRS denies exemption to a fee-based referral program
The IRS denied section 501(c)(3) exemption to an organization that connected designated community workers, military personnel, and other people with for-profit providers offering discounted…
IRS determination 1203024: IRS denies exemption to a foreclosure and credit counseling organization
The IRS denied section 501(c)(3) exemption to an organization planning to provide foreclosure prevention, loan modification, homebuyer, and credit counseling services. The organization charged…
IRS determination 1203023: IRS revokes exemption after private benefit and recordkeeping failures
The IRS revoked an organization's section 501(c)(3) exemption effective January 1 of the redacted year. The examination found that the organization routed contributed funds through related entities…
IRS determination 1203022: IRS revokes exemption for personal use of organizational assets
The IRS revoked the organization's section 501(c)(3) exemption effective January 1 of the redacted year. The examination found that organizational assets were used for the president's personal…
IRS revokes a grocery trade association's section 501(c)(6) exemption
The IRS revoked a grocery trade association's section 501(c)(6) exemption, effective January 1 of the redacted year. The determination found that the organization's primary activities, including…
IRS revokes a carbon-offset organization's section 501(c)(3) exemption
The IRS revoked a carbon-offset organization's section 501(c)(3) exemption, effective January 1 of the redacted year. The determination concluded that the organization was not operated exclusively…
IRS revokes an organization's section 501(c)(3) exemption after reincorporation
The IRS revoked an organization's section 501(c)(3) exemption after it reincorporated in a different jurisdiction. The organization had first been incorporated in one state, lost its corporate…
IRS denies section 501(c)(6) exemption to an investor networking organization
The IRS denied section 501(c)(6) exemption to an organization serving investors, economic development agencies, and early-stage companies. The organization’s main activity was an annual conference…
IRS revokes section 501(c)(3) status of a foundation that sold donated boats
The IRS revoked a foundation's section 501(c)(3) exemption after finding that it was not operated exclusively for exempt purposes and had ceased operations. The examination report states that the…
IRS denies a charitable organization's tax exemption after no protest
The IRS issued a final adverse determination denying a nonprofit organization's application for exemption under IRC section 501(c)(3) after the organization did not protest a proposed adverse…
IRS denies exemption to a nonprofit formed to support a related HVAC business
The IRS denied a nonprofit organization's application for exemption under IRC section 501(c)(3). The organization was formed after a related HVAC business was told that creating a nonprofit could…
PLR 1152021: IRS approves debt funding for charitable set-aside expenditures
The IRS ruled that a private foundation may use loans to pay all or part of the costs of a construction project funded through previously approved IRC § 4942(g)(2) set-asides. The foundation serves…
IRS determination 1152020: IRS denies exemption to a farmers' market organization
The IRS denied tax-exempt status under IRC § 501(c)(3) to a farmers' market organization whose primary activities facilitated produce sales for its vendors. The organization planned to operate a…
IRS determination 1152019: IRS denies exemption to a mortgage mitigation counseling organization
The IRS denied tax-exempt status under IRC § 501(c)(3) to an organization that provided mortgage mitigation and foreclosure-prevention services. The organization spent most of its time preparing…
TAM 1151028: IRS advises that a community recreational path supports tax exemption
The National Office considered whether to revoke a foundation's tax-exempt status under IRC § 501(c)(3) because the foundation built and maintained a recreational path available to residents of a…
IRS determination 1151027: IRS denies exemption to a homeowners association
The IRS issued a final adverse determination denying a homeowners association exemption under IRC § 501(c)(4). The association maintained a lake portion, a road, and a natural area, but the IRS…
IRS determination 1151026: IRS denies exemption to a grant-funded mobile-home project
The IRS denied IRC § 501(c)(3) exemption to a proposed nonprofit that planned to obtain grants, build or lease mobile homes and cottages, and provide vocational training on property owned and…
Determination 1150036: IRS denied exemption to a single-brand technology standards organization
The IRS denied a technology standards organization's application for exemption under section 501(c)(6). The organization promoted a single branded technology, operated a certification program, and…
Determination 1150035: IRS denied exemption to a fine-dining organization
The IRS denied a fine-dining organization's application for exemption under section 501(c)(3). The organization planned public demonstrations, tastings, and fundraising events, but its activities…
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.