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 1122026: IRS revokes a foundation's exemption after it failed to provide records
The IRS revoked a foundation's tax-exempt status under IRC § 501(c)(3) after the organization failed to respond to repeated requests for records about its receipts, expenditures, activities, and…
PLR 1122025: IRS approves a charity's sale of a long-held leased property
The IRS ruled that a charitable educational organization could sell one long-held parcel of leased real property without losing its exemption under IRC § 501(c)(3). The organization planned a…
Determination 1122024: IRS revokes exemption after missing records and returns
The IRS revoked an organization's exemption under IRC § 501(c)(3) after it failed to provide records needed to examine its books and activities. The organization also failed to file required Form…
Determination 1122023: IRS revokes exemption after private benefits and missing records
The IRS revoked an organization's exemption under IRC § 501(c)(3) after finding that its president used organizational funds for cash withdrawals, personal expenses, payments to his wife, and a…
Determination 1122022: IRS revokes exemption for an organization operating unrelated businesses
The IRS revoked an organization's exemption under IRC § 501(c)(3) because its primary activities were operating a bill-paying center, a small grocery store, and a bait shop. The IRS found that these…
Determination 1121032: IRS denied exemption to a synagogue organization because of private inurement and inadequate disclosures
The IRS issued a final adverse determination to a religious organization that sought recognition as exempt under IRC § 501(c)(3) and classification as a church. The IRS found that the organization…
IRS determination 1121029: exemption denied to an insurance company
The IRS issued a final adverse determination that an insurance company did not qualify for exemption under IRC § 501(c)(15). The company provided commercial casualty and property insurance-type…
PLR 1121028: IRS approves a VEBA's plan to use remaining funds for employee benefits
The IRS ruled that a voluntary employees' beneficiary association (VEBA) could wind up after its sponsoring trade association ended its sponsorship and all participating employers obtained other…
IRS determination 1121027: football officials' organization loses labor exemption
The IRS proposed revoking an organization's exemption under IRC § 501(c)(5). The organization supplied football officials to a league, but its members were independent contractors who received Forms…
IRS determination 1121026: charter school's exemption revoked after dissolution and filing failures
The IRS revoked a charter school's exemption under IRC § 501(c)(3), effective December 29 of the redacted year. The school had discontinued operations, had been administratively dissolved by its…
IRS determination 1121025: private foundation exemption revoked for serving its founder
The IRS revoked a private foundation's exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The examination found no charitable activities or payments to the charities named in…
IRS determination 1121024: exemption revoked after years of inactivity
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization had conducted no exempt-purpose activities for several years and had no…
IRS determination 1121023: exemption revoked for failure to file required returns
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 establishing that it operated exclusively…
IRS determination 1121022: inactive private foundation loses exemption
The IRS revoked a private foundation's exemption under IRC § 501(c)(3), effective July 1 of the redacted year. The foundation had been inactive since its inception, conducted no regular financial…
IRS determination 1121021: foreclosure consulting organization denied section 501(c)(3) exemption
The IRS denied exemption under IRC § 501(c)(3) to an organization that planned to provide foreclosure-related consulting to homeowners, lenders, and investors. The IRS concluded that the…
IRS determination 1120037: exempt status revoked for inactivity and failure to file returns
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization failed to provide records needed to establish that it operated…
Determination 1120036: IRS denied 501(c)(3) exemption to an employee caucus serving a private interest
The IRS finalized its denial of tax-exempt status under IRC § 501(c)(3) to an employee caucus that primarily supported employees of a related company. The determination concluded that the…
Determination 1120035: IRS denied exemption and supporting-organization status to a trust making donor loans
The IRS denied tax-exempt status under IRC § 501(c)(3) to a trust that sought recognition as a Type III supporting organization under IRC § 509(a)(3). The determination focused on the trust's loans…
PLR 1120032: sale of long-held commercial property does not create unrelated business income
The IRS ruled that a charitable educational organization could sell one long-held commercial real estate parcel without jeopardizing its exemption under IRC § 501(c)(3). The organization had…
PLR 1120031: sale of a ground-leased parcel does not create unrelated business income
The IRS ruled that a charitable educational organization could sell the leased-fee interest in a ground-leased commercial parcel without jeopardizing its exemption under IRC § 501(c)(3). The…
PLR 1120030: sale of a ground-leased parcel does not create unrelated business income
The IRS ruled that a charitable educational organization could sell the leased-fee interest in a ground-leased commercial parcel without jeopardizing its exemption under IRC § 501(c)(3). The…
PLR 1120029: sale of a ground-leased parcel does not create unrelated business income
The IRS ruled that a charitable educational organization could sell the leased-fee interest in a ground-leased commercial parcel without jeopardizing its exemption under IRC § 501(c)(3). The…
PLR 1120028: sale of a bequeathed ground-leased parcel does not affect exemption or create unrelated business income
The IRS ruled that a charitable educational organization could sell the leased-fee interest in a ground-leased commercial parcel without jeopardizing its exemption under IRC § 501(c)(3). The…
IRS determination 1119036: exemption denied for proposed student housing organization
The IRS issued a final adverse determination denying tax-exempt recognition under IRC § 501(c)(3) to an organization that planned to build and operate housing for college students, ROTC…
IRS determination 1119035: exempt status revoked for failure to file Form 990
The IRS revoked an organization's tax-exempt status under IRC § 501(c)(3). The organization did not provide information about its receipts, expenditures, or activities, and therefore did not…
IRS determination 1119034: exemption revoked for private benefit and unsupported payments
The IRS revoked an organization's exemption under IRC § 501(c)(3). The organization operated debt-relief and foreclosure-assistance programs that the IRS found were primarily fee-for-service or…
Determination 1118022: IRS revokes an organization's tax exemption after missing records and Form 990 requests
The IRS revoked an organization's tax exemption under IRC § 501(c)(3) after the organization failed to provide requested records and information, including a Form 990 or an explanation for not…
IRS denies tax-exempt status to a fee-based bankruptcy counseling organization
The IRS denied section 501(c)(3) exemption to an organization that planned to provide bankruptcy counseling and related online services for fees. The determination found that the organization had a…
IRS revokes exemption for a dog club focused on shows and obedience training
The IRS revoked a dog club’s section 501(c)(3) exemption after concluding that its primary activities were dog shows, sanctioned matches, and obedience training. The determination found that the…
PLR 1117034: Organizational amendments did not affect a charity's tax-exempt status
An organization supporting people with neurological impairment asked whether changes to its organizational documents would affect its section 501(c)(3) exemption. The changes removed one exempt…
PLR 1117025: Homeowners association received more time to elect section 528 treatment
The IRS granted a condominium management association 120 days from the ruling date to make its section 528 elections for the covered taxable years. The association had not filed income tax returns…
PLR 1117024: Homeowners association received more time to elect section 528 treatment
The IRS granted a condominium management association 120 days from the ruling date to make its section 528 elections for the covered taxable years. The association had not filed income tax returns…
Other 1116046: IRS revoked a section 501(c)(3) exemption for inactivity and private benefit
The IRS issued a final adverse determination revoking an organization's tax exemption under IRC § 501(c)(3), effective July 1, 20XX. The IRS said the organization was not operated exclusively for an…
Determination 1116033: IRS revoked a section 501(c)(3) exemption after recordkeeping failures
The IRS revoked an organization's tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The IRS said the organization failed to produce documents showing that it operated exclusively for…
Determination 1116032: IRS revoked a section 501(c)(3) exemption for recordkeeping failures
The IRS revoked an organization's tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization failed to meet the recordkeeping and reporting requirements under IRC §§ 6001 and…
Determination 1116031: IRS revoked an exemption while private-foundation filing duties continued
The IRS revoked an organization's tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization failed to establish that it operated exclusively for exempt purposes and did not…
Determination 1116030: IRS denied exemption to a brand-specific dealer advertising organization
The IRS denied tax exemption under IRC § 501(c)(6) to an organization formed by dealers of particular vehicle brands. The organization used cooperative advertising contributions to promote those…
Determination 1116028: IRS denied exemption to a technology-project funding platform
The IRS denied tax exemption under IRC § 501(c)(3) to an organization that planned to operate an online platform for funding public-interest technology projects. The IRS found that the organization…
IRS reclassified a supporting organization as a private foundation
The IRS reclassified a redacted organization from a section 509(a)(3) supporting organization to a private foundation, effective January 3, 2002. The organization remained recognized as exempt under…
IRS denied exemption to a proposed nonprofit tied to for-profit businesses
The IRS denied section 501(c)(3) recognition to a proposed nonprofit that planned to provide low-cost HVAC services and job training. The organization's founders also owned a for-profit HVAC…
IRS revoked a nonprofit's tax-exempt status for private benefit and reporting failures
This final adverse determination concerned a redacted nonprofit corporation that said it would pursue international student exchange, scholarships, and work-study programs. The IRS found no evidence…
IRS denies 501(c)(3) status to a virtual collaboration and education organization
The IRS issued a final adverse determination denying federal tax exemption under section 501(c)(3) to an organization that operated in a virtual collaborative environment. The organization offered…
Determination 1113049: IRS revokes an organization's section 501(c)(3) exemption after it failed to respond
The IRS revoked an organization's tax exemption under IRC § 501(c)(3). The organization did not provide records, file required information returns, or respond to repeated IRS requests needed to…
IRS revokes an organization's section 501(c)(3) exemption after repeated private-benefit transactions
The IRS revoked an organization's exemption under IRC § 501(c)(3) after finding repeated private-benefit and inurement transactions involving its president and family-run governing board. The…
IRS denies exemption to a foreign-grant conduit tied to a for-profit company
The IRS denied exemption under IRC § 501(c)(3) to an organization that planned to collect U.S. donations and route grants to foreign organizations. The applicant relied on a related for-profit…
PLR 1113035: IRS approves a charity's sale of a long-held leased property
An educational charity planned to sell a long-held parcel of real property that had been acquired largely by bequest and ground-leased to an unrelated tenant. The charity intended to sell the…
PLR 1113034: IRS approves amendments to a community trust's governing structure
A community trust planned to amend its governing resolution by expanding its distribution committee, changing several appointing roles, and updating quorum and voting rules. The trust represented…
IRS determination 1111015: social club exemption revoked after excessive nonmember income
The IRS revoked a golf and social club's exemption under section 501(c)(7), effective January 1, 20XX. The club's nonmember receipts were 20%, 23%, and 25% of gross receipts in the three years…
IRS determination 1111014: charitable exemption revoked after organization failed to file and provide records
The IRS revoked an organization's exemption under section 501(c)(3), effective July 1, 20XX. The organization failed to establish that it operated exclusively for exempt purposes and that no private…
IRS determination 1211026: IRS denies exemption to organization linked to a for-profit restaurant
The IRS denied tax-exempt status under IRC § 501(c)(3) to an organization formed around a for-profit restaurant and a grant-writing business. The organization proposed using grants and donations to…
IRS determination 1211025: IRS denies exemption to a research organization linked to private therapy businesses
The IRS denied tax-exempt status under IRC § 501(c)(3) to a proposed research organization whose work was based on methods developed and used by an insider's private therapy businesses. The…
IRS determination 1110020: charitable exemption revoked after conservation easement and reporting failures
The IRS issued a final adverse determination revoking an organization's exemption under section 501(c)(3), effective January 1, 2003. The organization held conservation easements, but the IRS found…
PLR 1110013: member assessment rebates do not jeopardize business league exemption
The IRS ruled that a state-created organization qualifying as a section 501(c)(6) business league could rebate surplus member assessments without losing its tax-exempt status. The organization…
IRS determination 1110012: IRS denies exemption to an amateur-sports advocacy organization
The IRS denied an organization's application for exemption under IRC § 501(c)(3). The organization described plans to monitor amateur athletics, promote fairness, provide possible educational…
IRS determination 1109029: rainwater bottling organization denied exemption over commercial operations and private benefit
The IRS finalized its denial of tax-exempt status to an organization formed to collect, bottle, and sell rainwater and generate hydroelectric power. The organization’s founder and family owned a…
IRS revokes a hospital’s exemption after it converts to a union-member VEBA
The IRS revoked an organization’s exemption under IRC § 501(c)(3), effective August 31, 20XX, after it amended its governing documents to remove charitable language and become a voluntary employees’…
Determination 1108048: The IRS revoked an organization's tax-exempt status
The IRS issued a final adverse determination revoking an organization's exemption under IRC § 501(c)(3). The determination states that the organization was not operated exclusively for exempt…
Determination 1108042: IRS finalizes denial of an organization's tax-exempt status
The IRS finalized its proposed denial of an organization's application for recognition as a section 501(c)(3) organization after no protest was received within 30 days. The determination states that…
Determination 1108041: IRS denies exemption to a foreclosure-services organization
The IRS finalized its denial of tax-exempt status for an organization that provided foreclosure-related services and professional development to its members. The determination states that the…
Determination 1108040: IRS revokes a fraternal organization's tax exemption
The IRS proposed revoking a fraternal organization's tax-exempt status after finding that it did not establish a genuine membership with a common calling, bond, or vocation. The examination also…
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.