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.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
Supporting organization lost exemption after scholarship activity stopped
A tax-exempt supporting organization existed to fund scholarships for students connected with a supported public charity. It had not awarded scholarships or otherwise distributed funds for the…
Inactive nonprofit lost exemption after incomplete dissolution
A supporting organization told the IRS that it had ended operations, filed a final Form 990-EZ, and distributed its remaining assets to another section 501(c)(3) organization. It relied on a state…
Shopping-center association denied business-league exemption
A commercial condominium association sought exemption as a business league under section 501(c)(6). Its member merchants paid fees and assessments that funded maintenance, repairs, landscaping,…
Hereditary-society umbrella group denied charitable exemption
An association sought section 501(c)(3) status for helping founders create hereditary and lineage societies. It advised new groups about bylaws, officer duties, fees, insignia, applications, bank…
Rural business group denied charitable exemption
An unincorporated, member-driven organization sought section 501(c)(3) status while supporting businesses in a small rural community. Its activities included vendor fundraisers, holiday events,…
Counseling subsidy group denied reinstatement
An organization whose exemption had been automatically revoked sought reinstatement under section 501(c)(3). It raised donations to subsidize counseling and coaching supplied by a particular life…
Cook-off fundraising group denied charitable exemption
A group sought section 501(c)(3) status for raising money through cooking competitions and related fundraising. Donations and sponsorships paid entry fees, food, beverages, cooking supplies, and…
Charity reclassified after it stopped operating a hospital
A section 501(c)(3) organization had been classified as a hospital under section 170(b)(1)(A)(iii). After it sold the hospital, its remaining operations were a home health service and a skilled…
Foreign-support charity reclassified as publicly supported
A section 501(c)(3) organization had been classified as a Type III functionally integrated supporting organization while supporting an organization formed outside the United States. Treasury…
Exemption revoked after organization ignored examination requests
A section 501(c)(3) organization did not respond to repeated IRS requests for records during an examination. The IRS sent certified and ordinary mail, checked the address with the Postal Service,…
School-support group reclassified as publicly supported
A volunteer organization supported a public school community through teacher grants, school events, family assistance, and improvement projects. It had been classified as a Type III non-functionally…
Exemption revoked over tax-preparation business and private benefit
A section 501(c)(3) organization shared bank accounts and operations with a for-profit tax-return preparation business owned and operated by insiders. Bank records showed individual tax refunds and…
Business membership group denied charitable exemption
An organization applied for section 501(c)(3) status with a mission of promoting the future growth of a defined business community. Its activities included business workshops, member meetings and…
Exemption revoked for missing records and apparent inurement
A section 501(c)(3) organization gave inconsistent accounts of its fundraising events, income, and expenses and did not provide adequate records for many bank transactions. The IRS found numerous…
Educational group denied social-club exemption
An organization applied for exemption as a social club under section 501(c)(7), but its main activity was holding educational events about a particular philosophy for members and the public. It…
Family reunion group denied charitable exemption
An organization applied for section 501(c)(3) status to organize recurring family reunions with meals at a hotel. Participation was limited to family members and friends, and fees were based on…
Community business group denied charitable exemption
An organization applied for recognition under section 501(c)(3) while operating much like a local chamber of commerce. Its charter promoted the civic, commercial, industrial, and agricultural…
Online matchmaking service denied social-club exemption
An organization sought section 501(c)(7) social-club status for an online dating and matchmaking service. Subscribers created accounts, answered survey questions, received recommended matches, and…
Hunting and fishing group denied charitable exemption
An organization applied for section 501(c)(3) status with purposes that included protecting wildlife, enhancing hunting and fishing, and uniting sportsmen. It gave members and their immediate…
IRS finds a self-declared 501(c)(4) "social welfare" group is really a political organization
This final IRS letter tells a group that had been treating itself as a tax-exempt social welfare organization (a self-declared 501(c)(4)) that it does not qualify, because its primary activity is…
Charity lost exemption after ceasing operations without formally dissolving
A section 501(c)(3) organization stopped its exempt activities and closed its bank account, but it did not complete the required steps to terminate formally. It did not file a final return, provide…
Community training organization denied farmers cooperative exemption
A nonprofit sought exemption under section 521 as a farmers cooperative. It planned educational training for youth, homeless individuals, and young entrepreneurs, including some instruction about…
Wargaming club denied charitable exemption
A club applied for section 501(c)(3) status to grow a wargaming community through in-person games and tournaments. It charged participation and membership fees, offered members free entry and guest…
Fraternal subordinate lost exemption after failing to provide records
A subordinate organization covered by a group ruling had been classified as a fraternal beneficiary society under section 501(c)(8). During an examination, it gave only sporadic and incomplete…
Charity lost exemption after ignoring record requests and making an unexplained payment
A section 501(c)(3) organization did not respond to repeated IRS requests for records needed to verify its continued exemption. Its return preparer told the examiner that the organization had never…
Social club lost exemption after gas rights income exceeded the nonmember limit
A social and recreation club entered an agreement to sell its gas and mineral rights. The resulting investment income and royalties consistently exceeded 35 percent of the club's total income, the…
Music and book activities served commercial and private interests
An organization sought section 501(c)(3) status for educational activities built around a book written by its sole director, free podcasts and online sessions, and fee-based custom music with…
Shooting range denied section 501(c)(3) status for recreational activity
An organization already exempt under section 501(c)(4) operated a shooting range open to members, the public, families, and law enforcement personnel. It offered firearms education and safety…
Private family cemetery denied section 501(c)(3) status
An unincorporated association applied for section 501(c)(3) status to maintain a privately operated family cemetery for cremated remains. Its bylaws limited plots and scattering rights to designated…
Community festival denied section 501(c)(3) status
An organization held a free annual community festival with live music, games, inflatables, crafts, and food vendors. It collected booth fees and sponsorships, used the proceeds to pay festival…
Student-aid group serving a for-profit school denied exemption
An organization formed by an employee of a for-profit school proposed paying books, supplies, class fees, and other education-related expenses for the school's students. Assistance was available to…
Classic-car club denied section 501(c)(3) status
An organization brought classic-car enthusiasts together for car shows, cruises, and social gatherings. It also planned a toy drive, shows at retirement homes, and drive-by cruises for sick and…
Exemption revoked after prolonged inactivity
The IRS revoked the section 501(c)(3) status of a supporting organization that had been inactive for approximately 12 years. The organization reported no bank account, general ledger, income,…
Independent strike fund denied labor-organization exemption
An organization sought exemption under section 501(c)(5) so it could operate a national strike fund for workers who lacked access to other strike funds. It planned to raise donations digitally and…
Large museum grant recognized as unusual
A publicly supported museum expected a very large grant and potential gift from an unrelated private operating foundation. The funds would build a new museum wing, improve the existing museum,…
Family genealogy group denied section 501(c)(3) status
An organization sought recognition as a tax-exempt educational organization under section 501(c)(3). It researched and shared the genealogy of one individual and that person's descendants,…
Private lake association denied section 501(c)(3) status
A lake association sought recognition as a charitable organization under section 501(c)(3). Its organizing document said it existed to promote fellowship among cottage owners and residents, regulate…
Tax-exempt status revoked for failing the operational test
The IRS revoked an organization's recognition as tax-exempt under section 501(c)(3). The final determination states that the organization failed the operational test because it could not show that…
Family reunion and genealogy organization denied exemption
An organization sought recognition as a charitable organization under section 501(c)(3) for activities centered on a twice-yearly family reunion. It presented one family's history, updated the…
Member-benefit organization denied section 501(c)(3) status
An organization sought recognition as a charitable organization under section 501(c)(3). Its activities included paying members' work-related legal fees, helping members with funeral costs for…
Commercial fitness gym denied section 501(c)(3) status
An organization planned to operate fitness gyms and use profits to support humanitarian and poverty-relief work. The gyms would be open to the public, employ paid managers and trainers, and charge…
Real estate trade association denied section 501(c)(4) status
A real estate trade association sought reinstatement as a section 501(c)(4) social welfare organization after its self-declared section 501(c)(6) status had been automatically revoked. Its bylaws…
Inactive school's section 501(c)(3) status revoked
The IRS revoked the section 501(c)(3) status of an organization that had previously been classified as a school under section 170(b)(1)(A)(ii). The organization stopped operating during the COVID-19…
Expanded clergy benefits continue to advance religion
A section 501(c)(3) organization has supported the widows and children of deceased clergy for more than 200 years through grants, stipends, and death benefits. It proposed increasing annual stipend…
IRS revokes a recreational club's 501(c)(3) status for operating as a business
This final IRS letter revokes the 501(c)(3) exemption of a recreational sporting club (its grounds include trap clubs). The club had been recognized years earlier as a public charity under Section…
Tax exemption denied for member health care sharing program
An organization sought section 501(c)(3) status for a faith-based health care sharing program. Members would pay monthly fees, and the organization would use subscription revenue to help pay…
IRS revokes a dormant self-declared church's 501(c)(3) status
This final IRS letter revokes the 501(c)(3) status of an organization that had held itself out as a church. Churches are exempt automatically and do not file Form 1023, so this organization had…
Exempt status revoked for failure to provide records
The IRS selected a section 501(c)(3) public charity's filing for examination and repeatedly requested financial, organizational, and operational records. The organization did not respond to mailed…
Farmers market association denied business league exemption
An unincorporated association operated two farmers markets where members paid fees to sell their products. The association managed the venues, provided insurance, advertised individual vendors and…
Exempt status revoked after years of inactivity
A section 501(c)(3) public charity had been dormant and out of operation for several years. Its current and prior Forms 990-EZ reported no income, expenses, assets, or liabilities for the periods…
Charity loses exemption after failing to provide records
The IRS revoked a charity's section 501(c)(3) status after the organization did not respond to repeated requests for its books, records, receipts, disbursements, and information about its…
Medical fundraiser denied charitable exemption
An organization formed to raise money for a designated individual's medical expenses applied for section 501(c)(3) status using Form 1023-EZ. It later acknowledged that it had no organizing…
Cat café denied agricultural organization exemption
A limited liability company operating a cat café and caring for adoptable rescue cats applied for exemption as an agricultural organization under section 501(c)(5). Its principal revenue came from…
Large health-care grant classified as unusual
A publicly supported charity expected a large grant from an unrelated section 501(c)(6) organization to create a program for patient-centered care and innovative practices serving mothers and young…
Members-only pier association denied exemption
An unincorporated association collected annual dues from a limited group of non-waterfront property owners to repair and maintain a pier. Only members and their accompanied guests could use the pier…
Veteran-group-owned LLC denied charitable exemption
A nonprofit limited liability company sought section 501(c)(3) status to raise money for a war memorial replica and distribute remaining funds to military charities. Its sole member was exempt under…
Social club exemption revoked for public business
A section 501(c)(7) social club operated a bar, golf course, pool, ballroom, and other facilities for members, guests, and nonmembers. Its returns showed recurring nonmember receipts above the…
Social club denied reinstatement because outside income was too high
A social club sought reinstatement of its section 501(c)(7) tax exemption after an earlier automatic revocation for failing to file required returns. The club received substantial income from…
Songwriting and book-promotion organization denied section 501(c)(3) status
An organization applied for section 501(c)(3) status to provide free educational podcasts and online sessions about a program described in a book published by its sole director. It also created…
Commercial publishing and private benefits defeat section 501(c)(3) exemption
An organization formed to spread the teachings of a spiritual author merged with a for-profit publisher and continued selling, licensing, and subscribing readers to the author's books and other…
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.