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 1131025: Teacher-supply website denied section 501(c)(3) exemption
The IRS finalized an adverse determination that a nonprofit website facilitating classroom-supply donations did not qualify for exemption under section 501(c)(3). Donors could use the website to…
Other 1131024: IRS revoked an organization’s section 501(c)(3) exemption for private benefit and inactive charitable operations
An organization recognized as a public charity under section 501(c)(3) was examined after its founder continued handling funds and property after resigning. The IRS found that the organization had…
PLR 1131004: IRS granted more time for homeowners association elections
A homeowners association's accounting firm filed Forms 1120 instead of the required Forms 1120-H for two taxable years. After discovering the error, the association requested additional time to…
IRS revokes an organization’s tax exemption because fundraising proceeds benefited specific families
The IRS revoked an organization’s section 501(c)(3) tax exemption because its only activity was operating a concession stand and distributing the proceeds to the parents who worked there. Those…
IRS denies exemption to a synagogue because its funds paid the founder’s personal expenses
The IRS denied a small synagogue’s application for recognition as a section 501(c)(3) organization. The organization transferred the founder’s home and mortgage to itself, paid the founder’s…
IRS denies exemption to a scholarship organization tied to a for-profit dance company
The IRS denied exemption to an organization that planned to award scholarships and grants for performing-arts education. The organization’s founders also owned for-profit dance companies, and the…
IRS denies exemption to a condominium association serving only its members
The IRS denied exemption to a 16-member condominium association under both sections 501(c)(6) and 501(c)(4). The association maintained hallways, a laundry room, a courtyard, and other common areas…
PLR 1130006: IRS approves a private foundation’s transfer of assets to another foundation
A private foundation planned to transfer about half of its assets, consisting of cash and securities, to another private foundation established to pursue separate charitable objectives. The IRS…
PLR 1130005: IRS approves a hospital-system reorganization without adverse tax consequences
The IRS approved a reorganization in which a public hospital authority would transfer management and healthcare operations to affiliated tax-exempt entities, including a merger of one healthcare…
Determination 1129056: IRS denies section 501(c)(3) exemption because activities served private interests
The IRS issued a final adverse determination denying an organization exemption under section 501(c)(3). The organization described its activities as investigating alleged academic misconduct and…
Determination 1129055: IRS revokes a debt-management organization's section 501(c)(3) exemption
The IRS revoked an organization's section 501(c)(3) exemption effective October 1, 2004. The organization provided credit counseling and debt management plans, but the IRS found that its primary…
Determination 1129043: IRS denied exemption to a children's television organization
The IRS denied tax-exempt status to a nonprofit that planned to produce educational children's television programs using characters and other intellectual property owned by a related for-profit…
Determination 1129042: IRS revoked exemption after an organization failed to provide examination records
The IRS revoked an organization's recognition as tax-exempt under section 501(c)(3) after the organization failed to provide information requested during an examination of its Form 990. The final…
Determination 1129041: IRS revoked exemption after an organization failed to substantiate its operations and records
The IRS revoked an organization's exemption under section 501(c)(3) after it failed to provide documents showing that it operated for exempt purposes and kept the required books and records. The…
IRS determination 1128038: IRS revokes a credit counseling organization's tax exemption
The IRS issued a final adverse determination revoking an organization's federal income tax exemption under § 501(c)(3), effective January 1, 2000. The IRS concluded that the organization was not…
IRS determination 1128037: IRS revokes a foundation's tax exemption after finding private benefit
The IRS issued a final adverse determination revoking a foundation's exemption under IRC § 501(c)(3), effective November 1, 2000. The IRS concluded that the foundation did not operate exclusively…
IRS determination 1128035: IRS revokes a social-welfare exemption for partisan training
The IRS issued a final adverse determination that an organization did not qualify for exemption under IRC § 501(c)(4). The organization operated a training program for people affiliated with a…
IRS determination 1128034: IRS revokes a social-welfare exemption for partisan training
The IRS issued a final adverse determination that an organization did not qualify for exemption under IRC § 501(c)(4). The organization trained and recruited members of a political party for…
IRS determination 1128032: IRS revokes a social-welfare exemption for partisan training
The IRS issued a final adverse determination that an organization did not qualify for exemption under IRC § 501(c)(4). The organization trained members of a political party for political office, and…
IRS determination 1128031: IRS revokes exemption after lodging activity and filing failures
The IRS issued a final adverse determination revoking a religious organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The organization offered lodging and…
IRS determination 1128030: IRS denies exemption for a marine technology program benefiting private businesses
The IRS denied exemption under IRC § 501(c)(3) to an organization formed to manage and fund a solar-powered marine transportation demonstration program. The organization planned to contract with…
IRS determination 1128029: IRS revokes exemption for an organization whose only activity was gaming
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The organization was formed to support medical and therapeutic services, but its only…
IRS determination 1128028: IRS denies exemption for a healthcare consulting organization serving foreign facilities
The IRS denied exemption under IRC § 501(c)(3) to a nonprofit membership corporation created by an exempt hospital to provide healthcare management, advisory, and consulting services around the…
Determination 1127017: IRS revokes an organization's tax-exempt status
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective on the date stated in the final determination. The organization failed to establish that it operated exclusively for…
Determination 1127016: IRS revokes an organization's tax-exempt status
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective on the date stated in the final determination. The organization failed to establish that it continued to operate for…
Determination 1127015: IRS revokes an organization's tax-exempt status
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective July 1 of the redacted year. The organization failed to establish that it operated exclusively for exempt purposes and…
IRS determination 1127014: IRS denies exemption to a housing and credit counseling organization
The IRS denied exemption under IRC § 501(c)(3) to an organization that proposed housing counseling, foreclosure prevention counseling, and financial education. The organization planned to charge…
PLR 1127013: IRS approves a hospital system's separate PAC and voluntary payroll deductions
A tax-exempt health care system asked whether it could establish and operate political action committees through a separate organization without jeopardizing its IRC § 501(c)(3) status. It also…
IRS determination 1126040: IRS revokes exemption for a fraternal organization operating a gaming club
The IRS revoked an organization's exemption after finding that it did not qualify as a fraternal beneficiary society under IRC § 501(c)(8). The organization operated a private club with video…
IRS determination 1126039: IRS denies exemption to health supplement research organization
The IRS denied exemption under IRC § 501(c)(3) to an organization that planned to research health maintenance and sell customized vitamin supplements. The organization also planned seminars and…
IRS determination 1126038: IRS denies insurance company exemption for concentrated risk
The IRS denied exemption under IRC § 501(c)(15) because the organization did not have enough insureds to create an adequate premium-pooling base. The IRS found that the organization's risks were too…
IRS determination 1126037: IRS denies exemption to organization formed to route grants to a related business
The IRS denied exemption under IRC § 501(c)(3) to an organization formed after a grant-writing company told its founder that a nonprofit was needed to obtain grant funding. The organization planned…
IRS determination 1126036: IRS denies exemption because an insurer's risks were too concentrated
The IRS denied exemption under IRC § 501(c)(15) to a foreign insurance company that elected under IRC § 953(d) to be treated as a domestic corporation. The company wrote insurance-type contracts and…
IRS determination 1126035: IRS revokes exemption after organization stops operating
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The organization had operated a group home for troubled children, but its corporate status…
IRS determination 1126034: IRS revokes exemption and identifies private-foundation expenditures as taxable
The IRS revoked a private foundation's exemption under IRC § 501(c)(3) after the foundation failed to provide books, records, and information needed to establish its exempt activities. The IRS also…
PLR 1126001: Late homeowners-association elections allowed for prior tax years
A homeowners association failed to file income tax returns or make the required elections for several tax years because its officers did not know about the filing requirements. The IRS determined…
IRS determination 1125045: Exemption denied for membership networking and homestay platform
The IRS issued a final adverse determination to an organization that operated a global membership website supporting online networking and member-arranged homestays. The organization sought…
IRS determination 1125044: Exemption denied for artists’ cooperative gallery
The IRS denied exemption under IRC § 501(c)(3) to an artists’ cooperative gallery that provided display and sales space for member artists. Although the organization conducted some educational…
PLR 1125043: Restructuring transfers preserve exemption and avoid unrelated business income
A public charity planned to transfer certain activities and assets to newly formed domestic and foreign for-profit subsidiaries, while retaining control and continuing its core educational and…
IRS determination 1125042: Online marketing and tuition assistance organization denied exemption
The IRS issued a final adverse determination to an organization that operated an online shopping website and earned commissions from affiliated retailers. The organization let shoppers direct those…
IRS revokes inactive organization's section 501(c)(3) exemption
The IRS revoked an organization's tax-exempt status under IRC § 501(c)(3). An examination found that the organization had been inactive for several years, had conducted no operations or financial…
IRS revokes organization's section 501(c)(3) exemption for failing to provide records
The IRS revoked an organization's tax-exempt status under IRC § 501(c)(3) after the organization failed to produce records supporting its continued qualification and did not respond to repeated…
IRS revokes charity's section 501(c)(3) exemption after records go unanswered
The IRS revoked an organization's exemption under IRC § 501(c)(3) after the organization failed to respond to repeated requests for documents about its activities and fiscal operations. The IRS…
IRS revokes organization's section 501(c)(3) exemption for non-exempt activity
The IRS revoked an organization's exemption under IRC § 501(c)(3) after finding that it was not operating exclusively for charitable, educational, or other exempt purposes. The organization’s…
IRS denies section 501(c)(3) exemption to commercial fundraising service
The IRS issued a final adverse determination after an organization seeking recognition under IRC § 501(c)(3) did not file a protest within 30 days. The organization planned web-based fundraising…
IRS approves amendments for a Type 1 supporting organization
The IRS ruled that a tax-exempt organization could amend its articles without losing its classification as a Type 1 supporting organization under IRC § 509(a)(3). The proposed changes would identify…
IRS denies a request to change a social-welfare group's exemption to section 501(c)(3)
The IRS issued a final adverse determination denying a national organization's request to modify its tax-exempt status from section 501(c)(4) to section 501(c)(3). The organization described…
PLR 1123045: IRS approves tax treatment for a hospital fitness center
The IRS ruled that a hospital's medical rehabilitation and fitness center furthered the hospital's exempt purposes. The center offered rehabilitation, physical therapy, health and wellness…
PLR 1123044: IRS approves endowment-pool treatment for charitable trusts
The IRS approved a university's proposed treatment of investments by two charitable remainder trusts in the university's general endowment pool. The IRS ruled that issuing, holding, redeeming, and…
PLR 1123043: IRS approves capital and unrelated-business-income treatment for endowment pool units
The IRS approved a university's proposed investment of a charitable remainder unitrust in units of the university's general endowment pool. It ruled that the pool-unit arrangement, distributions,…
PLR 1123042: IRS approves capital and unrelated-business-income treatment for endowment pool units
The IRS approved a university's proposed investment of a charitable remainder unitrust in units of the university's general endowment pool. It ruled that the pool-unit arrangement, distributions,…
IRS finalizes denial of section 501(c)(3) group-ruling modification for subordinate clubs
The IRS finalized its adverse determination that subordinate clubs in a group ruling did not qualify for exemption under section 501(c)(3). The clubs remained exempt under section 501(c)(4), but…
IRS revokes section 501(c)(19) exemption for a veterans organization operating a public bar
The IRS revoked a veterans organization's section 501(c)(19) tax exemption effective on the date stated in the final letter. The organization operated a bar that was open to members and the general…
IRS revokes section 501(c)(3) exemption after organization fails to provide examination records
The IRS revoked an organization's section 501(c)(3) exemption after repeated requests for examination information went unanswered. The organization did not provide records needed to establish that…
PLR 1123038: IRS treats a rural telephone cooperative's cellular-network sale gain as patronage-sourced income
The IRS ruled that gain from a rural telephone cooperative's sale of its interest in a cellular-services enterprise was patronage-sourced income. The cooperative had invested in the enterprise to…
PLR 1123037: IRS allows a cooperative to surrender its 501(c)(12) exemption by filing a final Form 990
An electric generation and transmission cooperative exempt under IRC § 501(c)(12) asked whether it could voluntarily surrender its exemption and operate as a taxable, for-profit cooperative by…
PLR 1123036: IRS approves a nonprofit's restructuring but declines its public-charity reclassification request
An educational nonprofit asked whether it could transfer some activities and assets to for-profit subsidiaries without losing its exemption under IRC § 501(c)(3). It also asked whether income from…
PLR 1123035: IRS allows an electric cooperative to surrender its 501(c)(12) exemption by filing a final Form 990
An electric distribution cooperative exempt under IRC § 501(c)(12) asked whether it could voluntarily surrender its exemption and operate as a taxable, for-profit cooperative by filing a final Form…
Determination 1122028: IRS denies exemption to a spa retreat and bottled-water organization
The IRS denied tax-exempt status to an organization that planned to operate paid spa retreats, provide spiritual and health services, and manufacture and sell bottled mineral water. The IRS…
Determination 1122027: IRS denies exemption to an organization that did not establish its church status or exempt operations
The IRS denied tax-exempt status under IRC § 501(c)(3) to an organization that described itself as a church or religious organization. The organization submitted multiple inconsistent organizing…
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.