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 1037039: IRS revoked an organization's section 501(c)(3) exemption
The IRS issued a final adverse determination revoking an organization's recognition as exempt under IRC § 501(c)(3), effective January 1, 2004. The organization was structured as a trust and claimed…
Determination 1037037: IRS denied exemption to a pharmaceutical research organization
The IRS finalized a proposed denial of exemption for a nonprofit clinical research organization. The organization conducted pharmaceutical-sponsored studies involving hepatitis B and hepatic…
Determination 1037036: IRS proposed revocation of a veterans organization's exemption
The IRS examined a veterans organization that operated a bar and related entertainment activities while claiming exemption under IRC § 501(c)(19). The report questions whether the organization…
Determination 1037035: IRS revoked a veterans organization's exemption
The IRS revoked an existing exemption under IRC § 501(c)(19), effective January 1 of a redacted year. The examination concerned a veterans organization that operated a bar and related entertainment…
Determination 1037034: IRS revoked a dormant section 501(c)(4) organization's exemption
The IRS issued a final adverse determination for a subordinate organization covered by a section 501(c)(4) group exemption. The organization had ceased operations, had no financial resources or…
Determination 1037033: IRS revoked a section 501(c)(3) organization's exemption
The IRS issued a final adverse determination revoking a section 501(c)(3) organization's exemption effective September 1 of a redacted year. The organization claimed to assist poor and needy…
Determination 1037032: IRS revoked a defunct section 501(c)(3) organization's exemption
The IRS issued a final adverse determination revoking a section 501(c)(3) organization's exemption effective January 1 of a redacted year. The organization had gone out of business, received no…
Determination 1037031: IRS revoked a section 501(c)(3) organization's exemption
The IRS issued a final adverse determination revoking a section 501(c)(3) organization's exemption effective August 1 of a redacted year. The organization failed to produce documents and respond to…
Determination 1037030: IRS revoked an animal-rescue organization's exemption
The IRS revoked a section 501(c)(3) animal-rescue organization's exemption effective January 1 of a redacted year. The organization said its purpose was to rescue abandoned horses, provide medical…
Determination 1037029: IRS revoked a youth dance organization's exemption
The IRS revoked a section 501(c)(3) youth dance organization's exemption effective January 1 of a redacted year. The organization conducted fundraising events through which parents of students at a…
Determination 1036031: IRS revoked an organization's section 501(c)(3) exemption
The IRS issued a final adverse determination revoking an organization's exemption under IRC § 501(c)(3), effective February 13, 2002. It found that the organization was not operated exclusively for…
Determination 1036030: IRS revoked an organization's section 501(c)(3) exemption for private benefit
The IRS issued a final adverse determination revoking an organization's exemption under IRC § 501(c)(3), effective January 1, 2006. It found that a substantial amount of the organization's assets…
Determination 1036025: IRS revoked an organization's exemption and section 509(a)(3) status
The IRS finalized its adverse determination that an organization did not qualify for exemption under IRC § 501(c)(3) after it failed to protest a proposed denial. The organization sought treatment…
Determination 1036024: IRS revoked a private school's section 501(c)(3) exemption over racial discrimination
The IRS finalized its adverse determination that a private school did not qualify for exemption under IRC § 501(c)(3), after the school failed to protest a proposed denial. The IRS found that the…
Determination 1035038: Exempt status revoked for private benefit
The IRS issued a final adverse determination revoking an organization's section 501(c)(3) exemption effective October 1, 2003. The IRS found that a substantial amount of the organization's assets…
IRS revoked a veterans' organization's section 501(c)(19) exemption for operating a public bar
The IRS revoked an exempt veterans' organization's status under IRC § 501(c)(19), effective March 1, 20XX. The examination report says the organization operated a bar and kitchen open every day to…
IRS revoked a booster club's section 501(c)(3) exemption for private benefit and inurement
The IRS revoked a booster club's exemption under IRC § 501(c)(3), effective February 1, 20XX. The examination report found that the club was closely associated with a related for-profit dance and…
IRS revoked a defunct organization's section 501(c)(3) exemption for private benefit and inurement
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective July 1, 20XX. The examination report states that the organization stopped operating its alternative schools after a local…
IRS revoked an inactive organization's section 501(c)(3) exemption for failure to operate
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 20XX. The examination report states that the organization had ceased operations, had no activities or income,…
IRS revoked an organization's section 501(c)(3) exemption for failure to provide records
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective October 1, 20XX. The final letter states that the organization failed to produce documents needed to establish that it…
IRS revoked an organization's section 501(c)(3) exemption after it ceased operations
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective June 30, 20XX. The organization had discontinued operations, entered liquidating bankruptcy, and filed a terminating Form…
IRS revoked a private foundation's section 501(c)(3) exemption after it stopped operating
The IRS revoked a private foundation's exemption under IRC § 501(c)(3), retroactively for years beginning on or after January 1, 20XX. The foundation had stopped operating and distributed its…
IRS revoked an inactive organization's section 501(c)(3) exemption for failing to keep records and file returns
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization was no longer operating, had not filed its required annual information return, and had…
IRS revoked an organization's section 501(c)(3) exemption after it failed to answer document requests
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization failed to produce documents or otherwise establish that it operated exclusively for…
IRS revoked an inactive organization's section 501(c)(3) exemption
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization had ceased operating, had no operational or financial activities, and had been…
IRS revoked an organization's section 501(c)(3) exemption for failing to respond to an examination
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization did not respond to repeated requests for information needed to examine its Form 990,…
IRS revoked an organization's section 501(c)(3) exemption for failing to provide information
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1, 20XX. The organization did not provide information requested on numerous occasions to substantiate its Form…
Determination 1033042: IRS revoked a credit-counseling organization’s section 501(c)(3) exemption
The IRS revoked an organization’s section 501(c)(3) exemption effective January 1, 2004. The organization’s primary activity was enrolling individuals in debt management plans, and the determination…
Determination 1033039: IRS revoked a private school’s section 501(c)(3) exemption
The IRS revoked a private school’s section 501(c)(3) exemption because the school failed to establish that it operated exclusively for exempt purposes and failed to overcome the inference of racial…
1032053: IRS revoked an organization's tax-exempt status and alternatively reclassified it as a private foundation
The IRS revoked an organization's recognition as exempt under section 501(c)(3), effective January 1, 2004. The IRS concluded that the organization was not operated exclusively for exempt purposes…
1032052: IRS revoked an organization's exemption for failure to file returns and provide records
The IRS revoked an organization's recognition as exempt under section 501(c)(3), effective January 1 of the specified year. The organization failed to file required Form 990-PF returns and did not…
1032051: IRS revoked an organization's exemption for failure to file returns and provide records
The IRS revoked an organization's recognition as exempt under section 501(c)(3), effective January 1 of the specified year. The organization failed to file required Form 990 returns and did not…
1032050: IRS revoked a mental-health organization's exemption for operating as a private practice
The IRS revoked the organization's recognition as exempt under section 501(c)(3), effective January 1 of the specified year. The IRS concluded that the organization operated a mental-health practice…
1032049: IRS revoked an organization's exemption for private benefit and bankruptcy-related issues
The IRS revoked the organization's recognition as exempt under section 501(c)(3), effective on the date of the final determination letter. The IRS concluded that the organization did not serve a…
1032048: IRS revoked an organization's exemption after raffle proceeds were diverted to private uses
The IRS revoked the organization's recognition as exempt under section 501(c)(3), effective January 1 of the specified year. The organization conducted raffles promoted as charitable activities, but…
1032047: IRS revoked an organization's exemption after it failed to provide records and respond to examination requests
The IRS revoked the organization's recognition as exempt under section 501(c)(3), effective July 1 of the specified year. The organization did not provide requested information, failed to keep…
1032046: IRS revoked a social club's exemption after nonmember receipts exceeded the permitted limits
The IRS revoked the organization's recognition as exempt under section 501(c)(7), effective April 1 of the specified year. The organization operated a restaurant and other facilities for members,…
1032045: IRS approved a social club's liquidating sale of real estate without revoking its exemption
The IRS ruled that a social club could sell its real estate, liquidate its assets, and dissolve without losing its section 501(c)(7) tax exemption. The club had operated recreational facilities for…
1032044: IRS approved a private foundation's transfer of half its assets to another private foundation
The IRS approved a proposed transfer of approximately half of one private foundation's assets to another private foundation. The transferor and transferee had similar charitable purposes, and the…
Determination 1031035: IRS denied a group ruling request to reclassify subordinate clubs under section 501(c)(3)
The IRS denied a national organization's request to modify its group ruling so that its subordinate clubs would qualify under IRC § 501(c)(3). The organization and its clubs conducted charitable and…
Determination 1031034: IRS denied exemption to a senior membership organization operating social trips and celebrations
The IRS denied tax-exempt status under IRC § 501(c)(3) to a membership organization for seniors. The organization held holiday celebrations, dinners, and sightseeing trips for members, and most of…
Determination 1031033: IRS denied a national organization's request for section 501(c)(3) exemption
The IRS denied a national organization's request for recognition under IRC § 501(c)(3). The organization conducted youth development and charitable programs, but the IRS concluded that its…
Determination 1031032: IRS denied exemption to a proposed school with incomplete operations and financial information
The IRS denied exemption under IRC § 501(c)(3) to a proposed school for students with learning disabilities or attention deficit disorder. The applicant had not begun operating, had not held board…
Determination 1030035: IRS denied exemption for a chiropractic organization
The IRS issued a final adverse determination that a chiropractic organization did not qualify for exemption under IRC § 501(c)(3). The organization was closely connected to a founder's for-profit…
Written Determination 1029041: Exempt status revoked for failure to substantiate continued qualification
The IRS revoked an organization's exemption under section 501(c)(3), effective on the stated date, because the organization failed to provide requested records and did not establish that it was…
Determination 1029038: IRS revoked a social club's tax exemption after finding private benefit and excessive nonmember activity
The IRS revoked a social club's exemption under IRC § 501(c)(7), effective May 1 of the redacted year. The examination found that bar and rental managers kept portions of the club's receipts, the…
Determination 1029037: IRS revoked a civic organization’s exemption after finding it did not operate as a social welfare organization
The IRS revoked a civic organization’s exemption under IRC § 501(c)(4), effective January 1 of the redacted year. The examination report found that the organization did not establish that it…
Determination 1029036: IRS revoked a charity’s exemption after finding its credit counseling activity was not operated for an exempt purpose
The IRS revoked the organization’s exemption under IRC § 501(c)(3), finding that it had not established that it operated exclusively for educational, charitable, or other exempt purposes. The report…
Determination 1029035: IRS revoked a charity’s exemption after finding repeated private benefit to its founder
The IRS revoked the organization’s exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The examination found that the founder received substantial private benefits through…
Determination 1029034: IRS revoked a charity’s exemption after it failed to substantiate its operations and file required returns
The IRS revoked the organization’s exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization failed to produce records or otherwise establish that it operated…
Determination 1029033: IRS revoked a dormant organization’s exemption after it failed to establish ongoing exempt operations
The IRS revoked the organization’s exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization failed to produce records establishing that it operated exclusively for…
Determination 1029032: IRS revoked a charity’s exemption after it used most of its assets to make insider loans
The IRS revoked the organization’s exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization had loaned 84 to 91 percent of its total assets to a substantial…
Determination 1029031: IRS denied exemption to a website-funded donation organization
The IRS denied the organization’s application for exemption under IRC § 501(c)(3). The organization operated a website and search engine that generated advertising revenue, and it proposed donating…
Determination 1029030: IRS revoked a charity’s exemption after it failed to file required returns and maintain records
The IRS revoked the organization’s exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization failed to produce documents showing that it operated exclusively for…
IRS determination 1028042: The IRS denied exemption to a membership organization that paid member funeral benefits
The IRS denied tax-exempt status under IRC § 501(c)(7) to a membership organization that provided financial assistance, including funeral benefits, to its members and their families. The…
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.