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 1045027: nonprofit opera organization loses exemption after inactivity
The IRS revoked an organization's section 501(c)(3) exemption after finding that it had not conducted activities in the relevant years. The organization had planned opera-related educational and…
Determination 1045026: organization loses exemption after failing to establish continued qualification
The IRS revoked the organization's section 501(c)(3) exemption effective January 1 of a redacted year. The organization did not establish that it operated exclusively for an exempt purpose, serve a…
Determination 1045025: organization loses exemption after failing to establish continued qualification
The IRS revoked the organization's section 501(c)(3) exemption effective January 1 of a redacted year. The organization did not provide records or respond to repeated requests needed to determine…
Other 1045024: IRS revokes an organization's section 501(c)(3) tax-exempt status
The IRS revoked an organization's section 501(c)(3) tax-exempt status. The document says the organization had ceased operations, did not file required annual Form 990 returns, and did not provide…
IRS revoked an organization's tax-exempt status and classified it as a private foundation
The IRS determined that an organization formed to preserve open space was a private non-operating foundation effective January 1, 2004, because it did not meet the public support tests. The IRS also…
IRS revoked an organization’s exemption after its original charitable purpose no longer existed
The IRS issued a final adverse determination that an organization no longer qualified for exemption under IRC § 501(c)(3). The organization had originally been established to operate a residential…
IRS confirmed exemption and modified an organization’s status to a private operating foundation
The IRS confirmed an organization’s exemption from federal income tax under IRC § 501(c)(3) after an appeal. It modified the organization’s foundation status to that of a private operating…
IRS classified an organization as a private foundation after it failed the public support test
The IRS determined that the organization was not a publicly supported charity under IRC § 509(a)(2). The released materials state that its public support test failed while its gross investment test…
IRS revoked an organization’s exemption after finding private benefit in down-payment assistance
The IRS issued a final adverse determination revoking an organization’s exemption under IRC § 501(c)(3), effective January 1, 2002. The organization provided down-payment assistance to home buyers…
IRS revoked an organization’s exemption after finding no charitable activity and insider control
The IRS revoked an organization’s exemption under IRC § 501(c)(3), effective January 1, 2003. The IRS stated that the organization had conducted no charitable activities and was structured in a way…
IRS revoked an organization's exemption after finding private benefit, insider inurement, and inadequate records
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The IRS found that the organization did not operate exclusively for exempt purposes, served…
PLR 1044019: IRS denied exemption to an online religious organization that did not meet organizational, operational, or church criteria
The IRS denied an application for exemption under IRC § 501(c)(3). The applicant was an unincorporated association that described plans for online religious discussions and distributions to people…
IRS denied exemption to a transportation provider that operated commercially
The IRS denied exemption under IRC § 501(c)(3) to an organization that planned to provide paratransit services for elderly and disabled people through contracts with healthcare organizations and…
IRS denied exemption after finding that a proposed nonprofit would benefit related private parties
The IRS denied exemption under IRC § 501(c)(3) to a proposed nonprofit that would take over activities from a for-profit assisted-living business. The proposed nonprofit was controlled by people…
IRS denied exemption to a website organization whose activities would benefit a for-profit subsidiary
The IRS denied exemption under IRC § 501(c)(3) to an organization that planned to connect the public with charitable opportunities through a social networking website. The organization also planned…
PLR 1044015: IRS approved a university's separation from a church and reorganization of its radio ministry
The IRS ruled that a university's planned separation from its affiliated church and reorganization would not adversely affect its tax-exempt status under IRC § 501(c)(3). The plan would change the…
IRS revoked a credit counseling organization's exemption after finding its fee-based services were not charitable
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 2005. The organization provided debt management plans and related credit counseling. The IRS concluded that…
PLR 1043050: IRS conditionally approved a modification to an amortization extension for unfunded pension liabilities
The IRS conditionally approved a plan's request to modify an existing ruling that allowed a 10-year extension for amortizing unfunded liabilities. The letter concerns liabilities described under IRC…
IRS determination 1043042: Online sports-fan organization denied social-club exemption
The IRS issued a final adverse determination to an internet-based organization formed to support a professional sports team. The organization operated a website and members-only forum, but it had…
PLR 1043041: IRS approved a charitable remainder trust’s foreign investment corporation structure
The IRS considered a charitable remainder unitrust’s request to use a wholly owned foreign corporation as an investment vehicle for U.S. and foreign hedge funds. The IRS ruled that the trust’s…
IRS 1042040: IRS denied exemption to a member service exchange
The IRS issued a final adverse determination denying federal tax exemption to an organization that coordinated reciprocal services among members. Members earned credits for services provided to…
IRS 1042039: IRS revoked exemption after an organization failed to file returns and provide information
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective on a redacted date. The organization failed to establish that it continued to operate exclusively for an exempt purpose,…
IRS 1042038: IRS revoked exemption after an organization failed to provide records
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective on a redacted date. The organization did not respond to repeated IRS requests to examine its records and had not filed an…
IRS denies section 501(c)(3) exemption to a reciprocal service exchange
The IRS issued a final adverse determination denying exemption under IRC § 501(c)(3) to an organization that coordinated reciprocal exchanges of personal services among members. The organization…
IRS denies section 501(c)(3) exemption to a childcare scholarship organization
The IRS issued a final adverse determination denying exemption under IRC § 501(c)(3) to an organization that planned to provide childcare scholarships, tutoring, and recreational classes. The…
IRS denies section 501(c)(3) exemption to a private school
The IRS issued a final adverse determination denying exemption under IRC § 501(c)(3) to a private school. The school was formed during court-supervised desegregation, had previously been denied…
IRS denies exemption to a fee-based paratransit organization
The IRS issued a final adverse determination denying section 501(c)(3) exemption to an organization that planned to provide paratransit services for elderly and disabled people through healthcare…
IRS revokes an organization's Section 501(c)(3) exemption for failing to provide records
The IRS revoked an organization's tax-exempt status under Section 501(c)(3), effective January 1, 20XX. The organization failed to respond to repeated requests for records and failed to file the…
Determination 1040037: IRS revokes a social club's tax exemption
The IRS revoked a social club's federal income tax exemption under IRC § 501(c)(7), effective 10/1/XX. The determination says the club had closed, had no books and records available for examination,…
Determination 1040036: IRS revokes exemption from a social and recreational organization
The IRS revoked an organization's federal income tax exemption under IRC § 501(c)(3), effective August 9, 20XX. The organization had been formed to promote minority family travel and camping…
Determination 1040035: IRS revokes an organization's tax exemption
The IRS revoked an organization's federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The final letter states that the organization was not operated exclusively for an…
Determination 1040034: IRS revokes a fraternal organization's exemption
The IRS revoked an organization's exemption under IRC § 501(c)(10), effective September 1, 20XX. The organization operated a bar and claimed to be a subordinate of a fraternal parent organization,…
Determination 1040033: IRS revokes a dissolved organization's exemption
The IRS revoked an organization's federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization had filed a final Form 990 with zeros on every line, did not file…
Determination 1040032: IRS revokes an organization’s tax exemption for lack of records
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective July 1, 20XX. The organization did not respond to repeated requests for records concerning its…
Determination 1040031: IRS revokes an organization’s tax exemption for lack of evidence
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective July 1, 20XX. The organization had not filed its required Form 990 and did not respond to repeated…
Determination 1040030: IRS revokes exemption from an education and research organization
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization was formed for Southeastern Indian education, research, and public…
Determination 1040029: IRS revokes an organization’s tax exemption for failure to respond
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization failed to provide information about its receipts, expenditures, or…
Determination 1040028: IRS revokes a dormant organization’s tax exemption
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization had ceased operations for several years and had been…
Determination 1040027: IRS revoked a dissolved organization's section 501(c)(3) exemption
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization had ceased operating, failed to keep required records, and failed to…
Determination 1040026: IRS revoked an organization’s section 501(c)(3) exemption after finding substantial non-exempt activities
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization’s activities included drum practice, bingo and other charitable…
Determination 1040025: IRS revoked a debt-management organization’s section 501(c)(3) exemption
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization’s primary activity was soliciting clients by telephone for debt…
Determination 1040024: IRS revoked an organization’s section 501(c)(3) exemption after finding a commercial purpose
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization had been recognized as tax-exempt but operated and described itself…
Determination 1040023: IRS revoked an organization’s section 501(c)(3) exemption for failing to file required returns
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective October 1, 20XX. The organization was formed to assist in locating missing children and had been…
Determination 1040022: IRS revoked a private foundation’s section 501(c)(3) exemption after loans benefited insiders
The IRS revoked an organization’s federal income tax exemption under IRC § 501(c)(3), effective January 1, 19XX. The organization was a supporting organization that distributed some income as grants…
Determination 1040020: IRS denied section 501(c)(6) exemption for an automobile dealer advertising association
The IRS denied exemption under IRC § 501(c)(6) to an association whose members were automobile dealers selling specific vehicle brands. The association’s purpose was to advertise and promote those…
Determination 1040019: IRS denied section 501(c)(4) exemption to a developer-controlled homeowners association
The IRS denied exemption under IRC § 501(c)(4) to a homeowners association serving a residential development. The association planned to maintain common areas and collect equal assessments from unit…
IRS determination 1039050: Exempt status revoked for failure to meet section 501(c)(3) requirements
The IRS issued a final adverse determination revoking an organization's tax-exempt status under IRC § 501(c)(3), effective on a redacted date. The determination states that the organization was not…
IRS determination 1039048: Housing program denied section 501(c)(3) exemption
The IRS issued a final adverse determination that an organization operating a housing program did not qualify for exemption under IRC § 501(c)(3). The organization planned to acquire, renovate, and…
IRS determination 1039046: Section 501(c)(3) exemption denied for private benefit to members
The IRS issued a final adverse determination denying an unincorporated association exemption under IRC § 501(c)(3). The organization held free home-buying workshops led by realtors, a mortgage…
IRS determination 1039045: Proposed revocation for failure to provide records and file Form 990
The IRS proposed revoking an organization's exempt status because it did not provide requested information and did not file Form 990. The Service explained that exempt organizations must submit…
IRS determination 1039044: Supporting organization reclassified as a private foundation
The IRS issued a final adverse determination revoking an organization’s recognition under IRC § 501(c)(3) as a supporting organization. The document states that the organization operated…
IRS determination 1039040: Section 501(c)(15) exemption revoked for insurance company
The IRS revoked an insurance company’s exemption under IRC § 501(c)(15), effective on a redacted date. The organization did not meet the newer two-part eligibility test because its premium income…
Determination 1039039: IRS revoked a fraternal organization’s exemption for operating a commercial bar
The IRS revoked an organization’s tax-exempt status under IRC § 501(c)(10), effective July 1, 20XX. The organization operated a commercial bar open to the general public, had no common fraternal…
Determination 1039038: IRS revoked a fraternal organization’s exemption for operating a commercial bar
The IRS revoked an organization’s tax-exempt status under IRC § 501(c)(10), effective April 1, 20XX. The organization operated a commercial bar, and its officer acknowledged that the organization…
Determination 1039037: IRS revoked an organization’s exemption after it used the status to obtain liquor licenses
The IRS revoked an organization’s tax-exempt status under IRC § 501(c)(10), effective January 1, 20XX. The organization operated a bar and used its claimed exemption to qualify for liquor licenses…
Determination 1039036: IRS revoked a social club’s exemption after nonmember income exceeded the statutory threshold
The IRS revoked a social club’s exemption under IRC § 501(c)(7), effective January 1, 20XX. The club operated a restaurant, bar, banquet hall, and golf course, and allowed nonmembers to use its…
Determination 1039035: IRS denied exemption for a proposed student-housing and marketing organization
The IRS finalized its denial of an organization’s application for exemption under IRC § 501(c)(3). The organization proposed developing market-rate student housing, operating a shuttle, and…
Determination 1039034: IRS revoked an airport operator’s exemption for commercial activity and private benefit
The IRS revoked an airport operator’s exemption under IRC § 501(c)(3), retroactive to January 1, 20XX. The organization owned and operated a private airport, earned rental and license-fee income…
IRS revoked a social club's tax-exempt status for excessive nonmember activity
The IRS Appeals Office considered an organization's appeal of the revocation of its exemption under IRC § 501(c)(7). The organization operated social and recreational facilities, but its nonmember…
Determination 1038015: IRS denied exemption to a single-brand software user association
The IRS issued a final adverse determination after an organization failed to protest a proposed denial within 30 days. The organization served public and private K-12 schools that used one software…
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.