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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Private foundation lost exemption after five years without exempt activity
A nonoperating private foundation was examined after reporting no operational or financial activity for five years. Its president said the organization lacked funding and resources and expected a…
Employee discount-card group does not qualify as a business league
An organization of local employers applied for exemption as a business league under Section 501(c)(6). It collected annual dues and provided member employees with a digital card offering discounts…
Hunting-dog club denied section 501(c)(3) status
An organization applied for recognition as a section 501(c)(3) charity based on activities involving the training and testing of versatile hunting dogs. It offered member-only training days,…
Cemetery organization denied section 501(c)(3) status
A nonprofit corporation applied for section 501(c)(3) status for cemetery activities that included selling burial plots, collecting maintenance fees, and maintaining a cemetery. It said the services…
Member welfare and recreation group denied section 501(c)(3) status
An organization applied for section 501(c)(3) status while describing its mission as promoting member welfare, recreation, fellowship, and common interests. Its activities included a memorial run…
Cemetery operator denied section 501(c)(3) status
A nonprofit cemetery operator applied for recognition under section 501(c)(3). Its activities consisted of selling burial plots, digging graves, maintaining cemetery property, offering burial and…
Charity loses 501(c)(3) status after its funds benefited insiders
The IRS revoked a public charity's 501(c)(3) status after an examination found that its money and accounts benefited people with private interests in the organization. The charity and a related…
Charity loses exemption after bank records show personal spending
The IRS revoked a charity's 501(c)(3) status after it repeatedly failed to provide records or explain its activities during an examination. Financial records obtained through summonses showed that…
Digital-asset rewards are taxable before a bankrupt platform freezes the account
A cash-method taxpayer received staking and other digital-asset rewards in an account before the platform froze customer accounts and filed for Chapter 11 bankruptcy. When credited, the rewards…
Rural cemetery denied section 501(c)(3) status
A nonprofit operating a small rural cemetery applied for section 501(c)(3) recognition. Its governing document was incomplete because it lacked signatures from at least two authorized individuals,…
Private foundation loses exemption for inactivity and insider-controlled assets
The IRS revoked a private foundation's 501(c)(3) status after finding that its purpose and operations had shifted away from the charitable program described in its exemption application. The…
Individually owned LLC denied section 501(c)(3) status
A single-member limited liability company applied for section 501(c)(3) recognition while proposing a food bank and a free senior center for low-income people. Its articles stated no exempt purpose,…
Dog performance club denied section 501(c)(3) status
A membership-based dog performance club applied for section 501(c)(3) recognition as an educational organization. It conducted sanctioned agility, obedience, tracking, scent work, and other trials,…
Rural tourism organization denied section 501(c)(3) status
An organization sought section 501(c)(3) status for programs intended to empower rural communities through tourism, business training, grants, education, and cultural preservation. Its current…
Community pickleball club denied section 501(c)(3) status
A community pickleball club applied for section 501(c)(3) recognition while describing its mission as providing healthy, recreational, competitive, and social activity and growing the sport locally.…
Running and yoga group denied section 501(c)(3) status
An organization applied for section 501(c)(3) status to promote physical fitness and healthy lifestyles among people in the restaurant and service communities. Its activities consisted mainly of…
Single-owner farm denied section 501(c)(5) status
A single-owner limited liability company sought exemption as an agricultural organization under section 501(c)(5). It operated a farm on property owned by its president and the president's spouse,…
Business networking group denied 501(c)(3) for member private benefit
A membership organization applied for 501(c)(3) status to help local startups and veteran-owned businesses through networking, education, referrals, discounts, promotional events, and grants for…
Religious loss-sharing plans denied 501(c)(3) as private insurance-like activity
A religiously affiliated organization applied for 501(c)(3) status while operating two loss-sharing programs for members' property and vehicles. Participants enrolled property, paid assessments…
Youth-golf fundraiser denied 501(c)(7) social-club status
An organization formed to raise money for youth golf programs applied for exemption as a 501(c)(7) social club. It planned to buy equipment for children, hold camps and events, and support golf…
Fundraising charity loses exemption after founder diverted revenue for personal use
The IRS revoked a fundraising charity's 501(c)(3) status after an examination found that its founder and sole active officer controlled its operations and used charity revenue for personal expenses.…
Purported church loses exemption for founder inurement and unsubstantiated activities
The IRS revoked the 501(c)(3) status of an organization that claimed to operate as a church. The organization did not substantiate regular religious services, a regular congregation, an established…
A large one-time grant to a community nonprofit is treated as an "unusual grant" that will not cost it public-charity status
A nonprofit that maintains parkland and runs community programs for residents of a large affordable-housing project asked the IRS to treat a big incoming grant as an "unusual grant." To keep…
Exemption denial became final after no protest
An organization applied for recognition as tax-exempt under section 501(c)(3). The IRS had sent a proposed adverse determination explaining the facts, law, and basis for denial, but the organization…
Residents' group denied 501(c)(3) for benefiting a facility's staff
A residents' group at a senior living facility applied to be recognized as a tax-exempt charity under Section 501(c)(3) using the streamlined Form 1023-EZ. Its two main activities were paying…
Members' association denied 501(c)(3) for member home-downpayment loans and tutoring
An unincorporated members' association applied to be recognized as a tax-exempt charity under Section 501(c)(3) using the streamlined Form 1023-EZ. Its two activities were pooling money to give…
Parade club denied 501(c)(7) social club status over nonmember bingo income
A membership organization that stages an annual parade and related member social events applied to be recognized as a tax-exempt social club under Section 501(c)(7). Its main source of money was…
501(c)(3) supporting organization's exemption revoked for inactivity
A charity that had been recognized as a tax-exempt "supporting organization" (a Section 509(a)(3) group that exists to support a specific public charity) had its exemption revoked. To keep 501(c)(3)…
Business-promotion group denied charitable status
An organization applied for section 501(c)(3) status to unite local businesses, industries, and civic organizations, promote trade, and conduct community events. Its activities included membership…
IRS revokes a fraternal society's 501(c)(8) exemption for not responding or keeping records
The IRS revoked the tax-exempt status of an organization that had been recognized as a fraternal beneficiary society under IRC Section 501(c)(8) through a group ruling. During an examination, the…
IRS revokes an inactive supporting organization's 501(c)(3) status
The IRS revoked the tax-exempt status of an organization that had been recognized as a public charity under IRC Section 509(a)(3), specifically a Type III non-functionally integrated supporting…
IRS denies 501(c)(3) status to a class-reunion organization
The IRS denied tax-exempt status under IRC Section 501(c)(3) to an organization formed to plan and hold class reunions and small gatherings for the members of a graduating class. To qualify as a…
IRS revokes exemption of a charity that stopped providing dialysis and now only rents its building
The IRS revoked the 501(c)(3) exemption of an organization that had originally been recognized as a charity because it promised to provide dialysis services and medical equipment at no cost to a…
IRS revokes a radio broadcaster's 501(c)(3) for inactivity and inurement to its officers
The IRS revoked the tax-exempt status of an organization that had been recognized as a 501(c)(3) public charity to run noncommercial educational radio broadcasting. Two problems drove the…
Employee social organization denied exemption
An employee activity organization sought recognition as a charitable organization under section 501(c)(3). It sold coffee and snacks slightly above cost and used fundraising proceeds to subsidize…
Condominium association denied exemption
A condominium owners' association sought exemption as a social welfare organization under section 501(c)(4). It used member dues and assessments to maintain shared building systems, gated parking,…
Member benefit pool denied exemption
An organization sought charitable exemption under section 501(c)(3) and stated a purpose of helping poor, hungry, homeless, and underprivileged people. Its primary current activity, however, was…
Family private-banking organization denied exemption
An organization sought exemption under section 501(c)(3) for activities it described as processing family transactions and providing private banking to identify one family's birthright and heritage.…
College athlete speaker program denied exemption
An organization raised donations to pay college athletes to give free motivational presentations at schools and community events. It contracted with a for-profit logistics company whose president…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better…
Local business group denied 501(c)(3) status for serving members' private interests
A local business group applied for recognition as a tax-exempt educational organization under Section 501(c)(3). It offered networking events, professional-development programs, online listings,…
Cattle-breed association denied 501(c)(3) status because member sales served private interests
An association of cattle owners and breeders applied for recognition under Section 501(c)(3). It held an annual show, meeting, banquet, and member sale, advertised members' cattle, and helped buyers…
Winery association denied 501(c)(3) status because promotion served member businesses
A regional winery association applied for recognition as an educational organization under Section 501(c)(3). It promoted member wineries through signs, brochures, maps, a website that directed…
Adult social club denied 501(c)(3) status because recreation was a substantial purpose
An adult social club applied for recognition under Section 501(c)(3), then asked to change its application to Section 501(c)(7). Its activities included dinners, plays, movies, picnics, winery…
Health-services organization lost exemption for private benefit and commercial activity
A health-services organization recognized under Section 501(c)(3) was examined after it shifted from its stated charitable, educational, and scientific purposes to providing paid services. The IRS…
Event organization lost exemption after failing the educational and recordkeeping tests
An organization recognized under Section 501(c)(3) primarily ran two annual public events, including one focused on commercial participants, and funded itself with admission revenue. It also…
Business-referral networking club denied 501(c)(6) status
A networking club applied to be recognized as a tax-exempt business league under Section 501(c)(6). Its members are business professionals who meet weekly to swap referrals ("leads"), give short…
Members' mutual death-benefit fund denied 501(c)(3) status
A membership organization applied for 501(c)(3) charitable status. Its main activity is pooling premiums paid by members and giving cash to any member who recently loses a close family member (a…
501(c)(3) status revoked for private inurement after directors routed donations to personal accounts
The IRS audited a small charity and found that its directors were using the organization to enrich themselves. The organization solicited donations online under its own name and Employer…
Green-hydrogen industry alliance denied 501(c)(3) status
An organization formed to advance clean ("green") hydrogen applied for 501(c)(3) charitable status. It raises public awareness of hydrogen as a zero-emission energy source, supports green-energy…
501(c)(3) exemption revoked after the organization stopped responding to IRS record requests
The IRS audited a 501(c)(3) organization and asked, repeatedly, for the records that every exempt organization must keep and produce: books showing its receipts, expenditures, and activities. The…
Anti-censorship web-tunneling developer denied 501(c)(3) status
An organization that writes software to defeat internet censorship applied for 501(c)(3) charitable status. Its technology lets users reach websites blocked in certain countries through a secure…
Local farmers' market denied 501(c)(6) business-league status
An organization that runs a local farmers' market applied to be recognized as a tax-exempt business league under Section 501(c)(6). It rents space to local farmers and producers (its "vendors," who…
IRS denies 501(c)(3) status to a charity built around paying student athletes for their name, image, and likeness
An organization set up as a Type I supporting organization of a public charity applied for 501(c)(3) status. Its function was to receive donations and coordinate arrangements in which partner…
IRS denies 501(c)(3) status to a member group paying death benefits and scholarships to members' families
An organization applied for 501(c)(3) charitable status using the streamlined Form 1023-EZ. It collected monthly dues from members and, in return, paid death benefits to members' families and…
IRS revokes a private school's 501(c)(3) exemption for failing the operational and recordkeeping tests
This is a final IRS revocation letter (Letter 6337) ending a private religious school's tax-exempt status under § 501(c)(3), along with the audit report (Form 886-A) that explains why. The school…
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.