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 1108039: IRS revokes a social club's tax exemption
The IRS revoked a golf club's tax exemption under IRC § 501(c)(7) after finding that the club operated its course for nonmembers and that nonmember use exceeded the applicable limits. The club's…
Determination 1108038: IRS revokes an inactive supporting organization's tax exemption
The IRS revoked the tax exemption of a Type 1 supporting organization under IRC § 501(c)(3) because it had remained inactive since its exemption was granted. The organization conducted no exempt…
PLR 1108037: Sale of an office building does not create unrelated business income
An IRC § 501(c)(3) organization planned to sell an office building that it partly used for its exempt activities and partly leased to unrelated tenants. The building was subject to refinanced debt,…
IRS determination 1107030: Social club tax exemption revoked
The IRS revoked a social club's exemption under section 501(c)(7), effective on the stated January 1 date. The examination materials concluded that the organization exceeded the 15 percent…
IRS determination 1107029: Social club tax exemption revoked
The IRS revoked a social club's exemption under section 501(c)(7), effective on the stated January 1 date. The examination report found that the organization did not maintain adequate records to…
IRS determination 1107028: Business networking organization denied exemption under § 501(c)(6)
The IRS issued a final adverse determination denying exemption to a business networking organization under IRC § 501(c)(6). The organization brought together professionals from different fields and…
PLR 1106019: IRS revises unrelated business income rulings for a seminary’s housing activities
The IRS reconsidered a 2006 ruling about whether a seminary’s housing revenue was unrelated business taxable income. It revoked or modified parts of the earlier ruling because the original facts did…
IRS determination 1106017: exemption revoked for failure to provide records and required returns
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization did not provide documents showing that it operated exclusively for…
IRS determination 1106016: exemption revoked after organization failed to provide records
The IRS determined that an organization did not qualify for exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization failed to provide books, records, and other…
PLR 1105050: Contract-unit payments for a charitable remainder trust are not unrelated business taxable income
The IRS approved an arrangement in which an exempt educational organization would allow a charitable remainder unitrust to buy contractual units tied to the organization's pooled endowment. The…
PLR 1105049: Contract-unit payments for a charitable remainder trust are not unrelated business taxable income
The IRS approved an arrangement in which an exempt educational organization would allow a charitable remainder unitrust to buy contractual units tied to the organization's pooled endowment. The…
Other 1105048: Beverage trade association denied exemption for providing particular services to members
The IRS issued a final adverse determination that a beverage-industry trade association did not qualify for exemption under IRC § 501(c)(6). The association negotiated supplier contracts, operated…
TAM 1105045: Universal service fund payments are income but excluded from the member-income test
Technical Advice Memorandum addressed federal and state universal service fund payments received by a rural cooperative telephone company. The IRS position was that the payments were income to the…
Other 1105044: Exemption revoked after a charity failed to file required annual returns
The IRS revoked a charitable organization’s exemption under IRC § 501(c)(3). The organization failed to file annual returns and did not respond to IRS requests for information about its receipts,…
PLR 1105043: Industry-wide communications registry program approved as substantially related to a trade association’s exempt purpose
The IRS approved a trade association’s program for assigning and registering a shared communications identifier that could be used across multiple carrier networks. The association would maintain a…
IRS determination 1105042: Exempt status revoked after organization failed to provide records
The IRS revoked a private foundation's tax-exempt status under IRC § 501(c)(3). The organization did not respond to repeated requests for an examination of its financial and operational records, and…
IRS denies tax-exempt status to a horse-preservation organization
The IRS denied section 501(c)(3) exemption to a nonprofit organization formed to preserve the genetic integrity of a particular horse breed and support related research and education. The…
IRS revokes exemption of a veterans organization operating public gaming activities
The IRS revoked a veterans organization's exemption under IRC § 501(c)(19). The organization operated gaming activities with the general public, received most of its income from those activities,…
IRS revokes exemption of a fraternal beneficiary society
The IRS revoked a fraternal beneficiary society's exemption under IRC § 501(c)(8). The organization did not follow its bylaws, held no regular general membership meetings, admitted members without…
IRS determination 1103063: IRS revokes exemption for a debt-management organization
The IRS revoked a debt-management organization's exemption under section 501(c)(3). The organization reported fee-based debt-management services, but the IRS found that it did not engage primarily…
IRS determination 1103062: IRS modifies a veterans organization's exemption to social-club status
The IRS modified an organization's tax-exempt status from a veterans organization under section 501(c)(19) to a social club under section 501(c)(7). The organization agreed to the change by signing…
IRS determination 1103061: IRS revokes exemption for an inactive supporting organization
The IRS revoked a supporting organization's section 501(c)(3) exemption because it had no assets, had never been active, and did not demonstrate activity furthering a charitable purpose. The…
IRS determination 1103057: IRS revokes exemption for a bingo organization without a charitable program
The IRS revoked an organization's tax exemption under IRC § 501(c)(3). The organization conducted weekly bingo games and represented that it raised money for scholarships, but the examination found…
IRS determination 1103056: IRS revokes exemption after private benefit and filing failures
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective July 1 of the redacted year. The determination states that the organization failed to operate exclusively for exempt…
IRS revokes an organization's tax exemption after it failed to provide records
The IRS revoked an organization's exemption under section 501(c)(3). The organization did not provide records and other information requested during an examination, despite repeated notices and…
IRS proposes revoking an organization's exemption after it stopped operating and filing required returns
The IRS proposed revoking an organization's exemption under section 501(c)(3). The organization stopped conducting activities consistent with its exempt purpose, its board dissolved, and it…
IRS revokes an organization’s exemption after finding private benefit and nonexempt operations
The IRS revoked an organization’s section 501(c)(3) exemption effective from its incorporation date. The determination states that the organization provided down payment assistance to home buyers in…
IRS denies exemption to a religious school
The IRS denied a religious school’s application for recognition as an organization exempt under IRC § 501(c)(3). The organization described a school, religious study and prayer services, but the IRS…
IRS denies tax exemption to an insurance company for inadequate risk distribution
The IRS denied an organization's request for exemption under IRC § 501(c)(15). The organization provided automobile damage and liability coverage for four related taxicab companies, but two insureds…
IRS revokes exemption from an inactive charitable organization
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(3). The organization had stopped operating and did not plan to resume exempt activities, while its historical activities…
IRS revokes exemption after private inurement findings
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(3). The examination report described transactions involving land, loans, and investments in companies connected to the…
IRS revokes exemption for failure to keep records and file reports
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(3). The organization had been administratively dissolved, did not provide records for examination, and did not file the…
IRS revokes exemption after an organization stops operating
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(3). The organization had stopped operating, failed to respond to repeated requests for records, and had not filed an annual…
IRS revokes exemption from an inactive charitable organization
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(3). The organization had been inactive during the examination years and reported no planned operations or financial…
IRS revoked an organization's section 501(c)(3) exemption for private inurement and private benefit
The IRS issued a final adverse determination revoking an organization's exemption under IRC § 501(c)(3), effective December 22, 2000. The determination states that the organization's application and…
IRS denies § 501(c)(3) exemption to a church-affiliated lending institution
The IRS issued a final adverse determination to an organization formed by members of several churches to provide loans and investment opportunities to church members. The organization argued that…
IRS determination 1050041: Exempt status revoked for failure to substantiate operations
The IRS revoked an organization's exemption under IRC § 501(c)(3) after the organization failed to produce records establishing that it operated exclusively for exempt purposes and that its earnings…
IRS determination 1050040: Exemption revoked for business league providing particular services
The IRS revoked a tax-exempt organization’s status under IRC § 501(c)(6). The organization served businesses in different industries and primarily provided human-resources information and consulting…
IRS determination 1050039: Exemption revoked for seller-funded down payment assistance program
The IRS revoked an organization’s exemption under IRC § 501(c)(3), retroactive to the date it began operating a seller-funded down payment assistance program. The program was open to home buyers…
IRS determination 1050038: Exemption revoked after organization failed to document dissolution
The IRS revoked an organization’s exemption under IRC § 501(c)(3), effective on a redacted date. The organization said it was dissolving but did not provide Articles of Dissolution, records showing…
IRS determination 1050036: Exemption revoked for fraternal organization operating commercial bar
The IRS concluded that a subordinate fraternal organization did not qualify for exemption under IRC § 501(c)(10). The organization operated a public bar, received substantially all of its income…
IRS determination 1050035: Exemption revoked after organization failed to provide examination records
The IRS revoked an organization’s exemption under IRC § 501(c)(3) after it repeatedly failed to provide records and information needed for an examination. The organization did not schedule an…
IRS determination 1050034: Exemption revoked for fraternal organization operating video lottery facility
The IRS recommended revoking a fraternal organization’s exemption under IRC § 501(c)(10). The organization’s roughly 250 members were allowed to join by completing a membership card to play video…
IRS determination 1050033: Exemption denied for gymnastics fundraising association
The IRS denied an application for exemption under IRC § 501(c)(3) by an association that raised money to offset the costs of children participating in a competitive gymnastics program at a…
IRS revokes an organization's § 501(c)(3) tax-exempt status
The IRS issued a final adverse determination revoking an organization's exemption under IRC § 501(c)(3), effective January 1, 2005. The IRS stated that the organization failed to segregate its…
PLR 1049047: Sale of a long-held charitable trust property will not create unrelated business income
A charitable trust that operated educational programs asked about selling one of eight commercial real estate parcels held for many years as an income-producing asset. The parcel was received by…
PLR 1049046: Housing organization may restructure through single-member LLCs without losing exemption
An organization exempt under § 501(c)(3) and classified under § 509(a)(2) planned to remove its sole member, operate without members under a board of directors, and hold affordable-housing…
IRS revokes exempt status after an organization failed to provide records and information
The IRS revoked an organization's exemption under § 501(c)(3), effective January 1 of the redacted year. The organization failed to establish that it operated exclusively for exempt purposes and…
IRS revokes exempt status after an organization failed to meet reporting requirements
The IRS revoked an organization's § 501(c)(3) exemption, effective January 1 of the redacted year. The organization did not establish that it operated exclusively for exempt purposes and failed to…
IRS 1049043: IRS denied exemption to an organization offering counseling and consulting services
The IRS issued a final adverse determination denying federal tax exemption to an organization that planned to provide counseling, financial consulting, seminars, and services to churches and…
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.