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 1150034: IRS denied exemption to a coffeehouse organization
The IRS denied a coffeehouse organization's application for exemption under section 501(c)(3). The organization planned to operate a multimedia café, support a related church and charities, and…
Determination 1150032: IRS denied section 501(c)(6) exemption to a single-technology trade group
The IRS denied exemption under section 501(c)(6) to a trade group focused on promoting one company's patented wireless technology and brand. The IRS concluded that the group served a segment of an…
Determination 1150031: IRS revoked a charitable organization's exemption for missing records
The IRS revoked a charitable organization's section 501(c)(3) exemption because the organization failed to provide books, records, and other information needed to establish its activities and…
IRS finalized denial of exemption for an organization testing green housing products
The IRS finalized its determination that an organization developing and beta-testing green residential products did not qualify for tax exemption under section 501(c)(3). The organization’s…
IRS denied exemption for a proposed supporting organization managing an LLC
The IRS finalized its determination that an organization formed to support a public charter school did not qualify for exemption under section 501(c)(3). The organization planned to manage an LLC…
IRS denied section 501(c)(4) exemption for a port management organization
The IRS finalized its determination that a nonprofit created by for-profit port operators did not qualify for exemption under section 501(c)(4). The organization provided management services,…
PLR 1149042: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
PLR 1149041: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
PLR 1149040: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
PLR 1149039: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
PLR 1149038: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
PLR 1149037: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
PLR 1149036: IRS approved a health-care system reorganization and supporting-organization structure
The IRS ruled on a proposed reorganization of an integrated health-care system that included a pediatric hospital, medical organizations, supporting organizations, and a for-profit insurance…
Determination 1149035: IRS revoked a charitable organization's exemption for operating commercial services
The IRS revoked a charitable organization's section 501(c)(3) exemption effective January 1, 20XX. It found that the organization's primary activities, including product ordering, shipping, and…
Determination 1149034: IRS revoked an organization's exemption for failing to substantiate its operations
The IRS revoked an organization's section 501(c)(3) exemption effective January 1, 20XX. The organization failed to produce records and other information requested during an examination of its Form…
PLR 1149032: IRS approved a local teachers' retirement fund dissolution and lump-sum distributions
The IRS ruled that a local teachers' retirement fund association could dissolve and distribute its remaining assets to members without losing its exemption under section 501(c)(11). The proposed…
Determination 1149031: IRS denied exemption to a fee-based financial planning organization
The IRS issued a final adverse determination after an organization failed to protest a proposed denial within 30 days. The organization offered financial education presentations and fee-based…
Homeowners association section 528 election requires consent to revoke
Chief Counsel Advice addressed whether a homeowners association that elected section 528 treatment by filing Form 1120-H could revoke that election. It concluded that revocation is permissible only…
Determination 1148008: IRS denies exemption to a scholarship organization tied to a for-profit study business
The IRS finalized its denial of exemption under IRC § 501(c)(3) to an organization that planned to provide scholarships for online college-credit examination preparation. The organization would…
Determination 1148007: IRS revoked an organization's tax-exempt status for non-exempt activity
The IRS revoked an organization's recognition of exemption under IRC § 501(c)(3), effective June 1 of the redacted year. The organization had not shown that it operated primarily for charitable,…
PLR 1147035: Community activity center will not affect exemption or create unrelated business income
An exempt charitable foundation asked whether acquiring, financing, owning, and operating a community activity center would affect its section 501(c)(3) status. The center would offer affordable…
IRS determination 1147034: Housing referral organization denied exemption
The IRS denied exemption to an organization that operated a website connecting short-term housing providers with visitors and patients' families. The organization claimed section 501(c)(6) status as…
IRS determination 1147033: Contest-based scholarships did not qualify for exemption
The IRS denied exemption to an organization that planned to award educational scholarships through a contest for young women. Contestants had to participate in talent, interview, swimsuit, and…
IRS determination 1146023: IRS revokes exemption from an organization that served a substantial nonexempt purpose
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective on the date stated in the letter. The determination says the organization was not operated exclusively for charitable,…
IRS determination 1146022: IRS revokes a social club's exemption for recurring public income
The IRS revoked a social club's exemption under IRC § 501(c)(7), effective January 1 of the redacted year. The examination found recurring income from bingo and other charitable gaming with the…
IRS determination 1146021: IRS revokes exemption after organization fails to provide records
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization failed to produce documents or otherwise establish that it was operated…
IRS determination 1146020: IRS revokes exemption after organization fails to provide records
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective October 1 of the redacted year. The organization failed to produce documents establishing that it was operated…
Determination 1145025: IRS denies exemption to a physician managed-care network
The IRS issued a final adverse determination that a nonprofit physician managed-care network did not qualify for exemption under IRC § 501(c)(3). The organization negotiated managed-care agreements,…
1144032: IRS revokes an organization's tax-exempt status
The IRS issued a final adverse determination revoking an organization's exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization had changed from free-market research to medical…
1144031: IRS revokes exemption for failure to keep records and file reports
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization failed to meet the recordkeeping and reporting requirements under IRC §§ 6001 and 6033,…
1144030: IRS denies section 501(c)(3) recognition to a breed association
The IRS finalized its determination that a membership association promoting a particular dairy breed did not qualify for exemption under IRC § 501(c)(3). The association's primary activities were…
Written determination 1143035: IRS revokes exemption after repeated private inurement
The IRS revoked a daycare organization's recognition as exempt under § 501(c)(3), effective January 1, 2003. The examination found repeated and substantial withdrawals and expenditures that were not…
Written determination 1143023: IRS denies exemption because housing activities served commercial and private interests
The IRS denied an organization’s application for recognition under § 501(c)(3). The organization proposed foreclosure counseling, financial counseling, affordable housing, down-payment assistance,…
PLR 1143022: IRS approves a private foundation's endowment grant and related award program
The IRS ruled that a private foundation's endowment grant to another private foundation would support exempt charitable, educational, and scientific purposes and would not jeopardize the grantor's…
PLR 1143021: IRS approves discounted redemption of electric cooperative capital credits
The IRS ruled that an electric cooperative could adopt a voluntary program to redeem current, former, and deceased members' patronage capital credits at their present value before the cooperative's…
Written determination 1143020: IRS denies exemption because member activities created substantial private benefit
The IRS issued a final adverse determination denying a membership organization exemption under § 501(c)(3). The organization conducted frequent social and professional networking events, mentored…
Determination 1142029: IRS denies section 501(c)(3) exemption to a health and wellness center
The IRS denied section 501(c)(3) exemption to a proposed health and wellness center whose governing-body members would operate their own for-profit practices in the facility. The organization…
Determination 1142028: IRS revokes a credit-counseling organization's tax exemption
The IRS revoked a credit-counseling organization's section 501(c)(3) exemption after finding that its main activity was servicing debt-management plans rather than providing substantial educational…
Determination 1142027: IRS denies section 501(c)(4) status to a partisan political training program
The IRS denied section 501(c)(4) status to a nonprofit training program formed to inspire and train members of a political party to run for office. The program selected participants based on…
PLR 1142026: IRS rules oil and gas project debt is not the foundation's acquisition indebtedness
A private foundation planned to acquire net profits interests in oil and gas properties from an unrelated for-profit corporation. The foundation would pay cash and would not manage the properties,…
IRS 1141021: Exemption denied to fee-based consulting and telecommunications organization
The IRS finalized its denial of tax-exempt status under IRC section 501(c)(3) after the organization did not protest a proposed adverse determination within 30 days. The organization planned to…
IRS revokes exempt status of a down payment assistance organization
The IRS issued a final adverse determination revoking an organization's section 501(c)(3) exempt status effective January 1, 2007. The organization provided down payment assistance to home buyers,…
PLR 1140028: Sale of a stadium does not end a charity's scholarship-based exemption
The IRS ruled that a nonprofit organization could sell a baseball stadium and stop operating it without losing its exemption under IRC § 501(c)(3). The organization would use the sale proceeds and…
Determination 1139013: IRS revoked a credit counseling organization's exemption after finding its main activity was selling debt-management plans
The IRS issued a final adverse determination revoking a credit counseling organization's exemption under IRC § 501(c)(3), effective January 1, 2001. The IRS found that the organization operated…
Determination 1138054: IRS revoked a social club's exemption after persistent nonmember use of its facilities
The IRS revoked a social club's exemption under IRC § 501(c)(7). The club's nonmember receipts from facility use exceeded the 15 percent guideline for at least three years, and the club advertised…
Determination 1138050: IRS denied exemption to a group supporting a foreign religious school
The IRS denied exemption under IRC § 501(c)(3) to a group that solicited donations in the United States and sent them to a foreign religious school. The group could not document pre-grant inquiries,…
PLR 1136027: IRS approves an agricultural organization’s asset transfer upon dissolution
The IRS approved an agricultural organization’s plan to dissolve and distribute all or substantially all of its assets to another organization recognized as exempt under section 501(c)(5). The…
IRS revokes foundation's tax-exempt status under section 501(c)(3)
The IRS Appeals Office issued a final adverse determination revoking a foundation's exemption under IRC § 501(c)(3), effective January 1, 2007. The IRS concluded that the foundation's primary…
IRS revokes exemption for Main Street economic-development organization
The IRS issued a final adverse determination after an organization did not protest a proposed adverse determination within 30 days. The organization operated a Main Street program focused on…
IRS written determination 1134023: school property approved for charitable foundation purposes
A private foundation planned to use a wholly owned disregarded entity to acquire land, build a school, and lease the property to an unrelated public charity for a nominal rent. The foundation asked…
IRS revokes exemption for a small property and casualty insurance company
The IRS revoked an insurance company's exemption under IRC section 501(c)(15) after determining that its gross receipts exceeded the applicable limitation. The examination report said the…
PLR 1133013: IRS addresses a charity's conversion to private foundation status
A supporting organization sought to convert from public charity status to private foundation status while making a series of grants to the charity it supported. The IRS ruled that the conversion…
PLR 1133012: Charity can convert a supporting fund to a private foundation
An existing public charity asked whether a supporting fund could convert to private foundation status and make promised payments to the charity as part of that conversion. The IRS ruled that the…
IRS determination 1133011: Organization denied exemption as a section 501(c)(25) entity
The IRS issued a final adverse determination to an organization that described itself as a broker-dealer, accounts manager, clearinghouse, and private-to-private lending institution. The…
Determination 1132030: IRS revoked a credit counseling organization's section 501(c)(3) exemption
The IRS revoked the organization's section 501(c)(3) exemption, effective January 1, 2001, and concluded that contributions to it were not deductible under section 170. The organization offered…
PLR 1132027: IRS approved a private foundation's transfer of all assets to a successor corporation
The IRS ruled that a charitable trust could transfer all of its assets and operations, without consideration, to a state not-for-profit corporation that would seek recognition as a section 501(c)(3)…
PLR 1131029: Community-center activities and rental income excluded from UBIT
The IRS ruled that a religious organization’s planned community centers would further its exempt purposes through religious, educational, charitable, recreational, and social-service programs.…
PLR 1131028: VEBA may cover former spouses and limited impermissible benefits
The IRS ruled that a jointly administered employee-benefit fund could provide health coverage to former spouses who qualify as dependents under the tax rules. The fund could also provide health…
PLR 1131027: Supporting organization status continues after trust reorganization
The IRS ruled that a nonprofit supporting organization would continue to qualify as a section 509(a)(3) supporting organization of a trust and an affiliated corporation. The trust and corporation…
Determination 1131026: Child-care organization denied section 501(c)(3) exemption
The IRS finalized an adverse determination that a home-based child-care organization did not qualify for exemption under section 501(c)(3). The organization’s governing body consisted of a family,…
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.