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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Homeowners association denied exemption under Section 501(c)(4)
The IRS issued a final adverse determination to a homeowners association that sought exemption under IRC Section 501(c)(4). The association owned and managed recreational vehicle park and…
Commercial owners association denied exemption under Section 501(c)(4)
The IRS issued a final adverse determination to a commercial owners association that sought exemption under IRC Section 501(c)(4). The association maintained common assets for an industrial…
Employee aid organization denied exemption under Section 501(c)(3)
The IRS issued a final adverse determination to an employee aid organization that sought exemption under IRC Section 501(c)(3). The organization provided flowers, fruit baskets, and occasional…
Housing organization denied exemption under Section 501(c)(3)
The IRS denied exemption under IRC Section 501(c)(3) to an organization planning moderate-income housing, down-payment assistance, homebuyer education, and a realtor search tool. The organization…
Political coalition denied exemption under Section 501(c)(3)
The IRS denied tax-exempt status under IRC Section 501(c)(3) to an organization formed to unite political parties and oppose an incumbent president in upcoming elections. The organization planned to…
Religious teaching center denied exemption under Section 501(c)(3)
The IRS denied exemption under IRC Section 501(c)(3) to an unincorporated religious teaching center. The center had not submitted an organizing document, and its proposed dissolution terms would…
Church auxiliary does not have to file Form 990
An organization asked the IRS to determine whether it was exempt from filing Form 990. The IRS determined that the organization qualified as an integrated auxiliary of a church exempt from taxation…
Exempt status revoked after organization failed to provide records
The IRS issued a final determination that an organization did not qualify for federal income tax exemption under IRC Section 501(c)(3). The organization did not provide records about its receipts,…
IRS revokes a charity's exemption after it failed to provide audit records
The IRS revoked an organization's § 501(c)(3) status after it did not provide records requested during an audit. The IRS repeatedly mailed examination and delinquency notices and made numerous…
Community business and recreation group denied charity status
An organization formerly exempt as a business league sought recognition as a charity under IRC § 501(c)(3). Its governing documents continued to authorize promoting local business activity and…
Veteran business network denied social-welfare exemption
A mutual benefit corporation sought exemption under IRC § 501(c)(4) for a membership network serving veteran business owners, executives, and professionals. Its programs offered members referrals,…
Angel investor club denied business-league exemption
An accredited-investor membership club sought exemption as a business league under IRC § 501(c)(6). The club screened startup applications, hosted pitch dinners, shared investment information, and…
Religious education organization denied Section 501(d) exemption
A religious education organization sought exemption under IRC § 501(d) as a religious or apostolic organization. It trained church members for ministry and leadership, but its members did not live…
Gated homeowners association denied social-welfare exemption
A gated homeowners association sought exemption as a social-welfare organization under IRC § 501(c)(4). It owned and maintained the subdivision's streets, sidewalks, and other common areas, but…
Church auxiliary is exempt from filing Form 990
A section 501(c)(3) organization asked to be excused from filing the annual Form 990 information return. The IRS determined that the organization qualifies as an integrated auxiliary of a church…
Church auxiliary is exempt from filing Form 990
A section 501(c)(3) organization asked to be excused from filing the annual Form 990 information return. The IRS determined that the organization qualifies as an integrated auxiliary of a church…
Governmental affiliate is exempt from filing Form 990
A section 501(c)(3) organization asked the IRS to excuse it from filing the annual Form 990 information return. Section 6033(a)(3)(B) gives the IRS discretion to exempt certain organizations from…
Church-affiliated school is exempt from filing Form 990
A section 501(c)(3) school asked to be excused from filing the annual Form 990 information return. The IRS determined that it is an educational organization below college level with a general…
IRS revokes a member death-benefit association's 501(c)(4) status
A membership association collected dues and additional amounts when a member died, then paid the collected funds to the deceased member's family after deducting certain costs and retaining a…
IRS revokes an inactive charity's 501(c)(3) status
A charity had been recognized under section 501(c)(3) for a national movement, fundraising to assist other charities, and related administrative and promotional activities. During an IRS…
Dog club denied 501(c)(7) status because public revenue exceeded the limit
A dog club applied for exemption as a section 501(c)(7) social and recreational club. It held dog-sport demonstrations, public classes, pet photo events, and an amateur dog show, and it received…
IRS revokes an inactive charity's tax exemption
A charity had been recognized under section 501(c)(3), but state records showed that it had been dissolved and its representative confirmed that it had been inactive since a redacted date. The…
IRS denies charity status to a grant program benefiting a related business
An organization proposed to give financially needy young people grants for animal-assisted mental health coaching. Each grant could be used only at a for-profit business owned by a person holding a…
IRS denies charity status to a retriever training club
A retriever club sought section 501(c)(3) status as an educational organization. It offered public classes on human and animal first aid, conservation, and search and rescue, but it also trained…
IRS denies charity status to a private road association
A membership organization maintained dirt roads in a mountain community by collecting annual dues from local property owners. Its volunteers repaired roads, dug drainage ditches, spread road base,…
IRS denies agricultural exemption to a farmers' market operator
An organization operated a community farmers' market for local farms, small businesses, and nonprofits. Vendors paid a fee for promotion and a place to sell agricultural goods as well as books,…
IRS approves consolidation of related private foundations
A private foundation organized as a charitable trust proposed to transfer all its assets to a related private foundation organized as a nonprofit corporation. The foundations were controlled by the…
Church auxiliary is exempt from filing Form 990
A Section 501(c)(3) organization asked to be excused from filing the annual Form 990 information return. The IRS determined that the organization qualifies as an integrated auxiliary of a church…
IRS confirms a church's integrated auxiliary need not file Form 990
A church-affiliated organization asked the IRS to confirm it does not have to file Form 990, the annual information return most tax-exempt organizations must submit. Under Treasury Regulation…
IRS denies 501(c)(4) status to a condominium homeowners' association
A condominium homeowners' association applied for tax-exempt status as a section 501(c)(4) social welfare organization, and this is the IRS's final determination denying it (the group did not…
IRS revokes a 501(c)(3) that operated like a social club (bar, gaming, member events)
The IRS revoked a nonprofit's recognition as a tax-exempt charity under section 501(c)(3). The group had been recognized as a public charity, but on audit the IRS found it operated much like a…
IRS denies 501(c)(6) status to a business networking and referral group
A business networking and referral group applied for tax-exempt status as a section 501(c)(6) business league, and this is the IRS's final determination denying it (the group did not protest the…
IRS denies 501(c)(3) status to a members-only makerspace and art co-op
A community makerspace (a shared art and fabrication studio) applied for tax-exempt status under section 501(c)(3), and this is the IRS's final determination denying it (the group did not protest…
IRS denies 501(c)(4) status to an employee association that advocates for its members
An employee association applied for tax-exempt status as a section 501(c)(4) social welfare organization (specifically a local association of employees), and this is the IRS's final determination…
IRS denies 501(c)(4) status to a collectively-bargained employee benefit fund
A trust set up as a "Pooled Supplement Fund" applied for tax-exempt status as a section 501(c)(4) social welfare organization, and this is the IRS's final determination denying it (the group did not…
IRS denies 501(c)(8) status to a group that just buys members third-party insurance
A membership group applied for tax-exempt status as a section 501(c)(8) fraternal beneficiary society, and this is the IRS's final determination denying it (the group did not protest the earlier…
IRS denies 501(c)(6) status to a contractor "bid-ready" consulting group
A group that helps construction contractors become "bid ready" applied for tax-exempt status as a section 501(c)(6) business league, and this is the IRS's final determination denying it (the group…
IRS denies 501(c)(4) status to a mutual-aid group that pays death benefits to members' families
A mutual-aid membership group applied for tax-exempt status as a section 501(c)(4) social welfare organization, and this is the IRS's final determination denying it (the group did not protest the…
Church integrated auxiliary is not required to file Form 990
A tax-exempt organization asked the IRS to be excused from filing Form 990, the annual information return most exempt organizations must file. The IRS determined that the organization qualifies as…
501(c)(7) social-club exemption denied over public bingo income and missing member/non-member records
A membership social club, built around an annual parade and member socials, applied to be recognized as a tax-exempt social club under IRC Section 501(c)(7). The IRS denied the exemption. A…
501(c)(3) exemption denied to government-formed entity operating as a commercial bank
A government-created "semi-autonomous agency" that operates as a lending bank applied to be recognized as a charity under IRC Section 501(c)(3). The IRS denied it on both required tests. On the…
501(c)(3) exemption denied to a fee-based business-development consulting operation
An organization that provides business leadership, consulting, and technical assistance, initially focused on agribusiness development for entities abroad, applied to be recognized as a charity…
IRS confirms a church integrated auxiliary need not file Form 990
An organization that qualifies as an "integrated auxiliary of a church" asked the IRS to excuse it from filing the annual Form 990 (the information return most tax-exempt organizations must file).…
IRS excuses a church-affiliated school from Form 990, but requires annual Form 5578
A church-affiliated school below college level asked the IRS to excuse it from filing the annual Form 990. Treasury Regulation § 1.6033-2(g)(1)(vii) relieves an educational organization described in…
IRS confirms a church integrated auxiliary need not file Form 990
An organization that qualifies as an "integrated auxiliary of a church" asked the IRS to excuse it from filing the annual Form 990 information return. Treasury Regulation § 1.6033-2(g)(1)(i)…
IRS confirms a church integrated auxiliary need not file Form 990
An organization that qualifies as an "integrated auxiliary of a church" asked the IRS to excuse it from filing the annual Form 990 information return. Treasury Regulation § 1.6033-2(g)(1)(i)…
IRS denies § 501(c)(4) social-welfare exemption to a condominium homeowners' association
A condominium homeowners' association applied to be recognized as a tax-exempt social welfare organization under IRC § 501(c)(4). This is the IRS's final adverse determination: because the…
IRS denies § 501(c)(5) agricultural exemption to a livestock-breed sales association
A regional livestock-breed association applied for tax-exempt status as an agricultural organization under IRC § 501(c)(5). This is the IRS's final adverse determination, made final because the…
IRS denies § 501(c)(6) business-league exemption to a member-referral networking group
A member-referral networking group organized as an LLC applied for tax-exempt status as a business league under IRC § 501(c)(6). This is the IRS's final adverse determination, made final when the…
IRS denies § 501(c)(3) exemption to a single-member LLC ministry for failing the organizational and operational tests
A single-member LLC describing itself as a ministry, church, and school applied for recognition as a tax-exempt charity under IRC § 501(c)(3). This is the IRS's final adverse determination, made…
IRS denies § 501(c)(4) social-welfare exemption to a members-only mutual-aid society
A mutual-aid society made up of compatriots from one country applied to be recognized as a tax-exempt social welfare organization under IRC § 501(c)(4). This is the IRS's final adverse…
IRS confirms a church-affiliated mission society need not file Form 990
Most tax-exempt organizations must file a yearly information return (Form 990) with the IRS. A group asked to be excused from that requirement because it is a mission society. This letter is the…
IRS confirms a governmental-unit affiliate need not file Form 990
Tax-exempt organizations generally must file a yearly Form 990 information return, but the IRS has discretion to excuse some of them. A group asked to be relieved from that filing duty. This letter…
IRS confirms a governmental-unit affiliate need not file Form 990
Tax-exempt organizations generally must file a yearly Form 990 information return, but the IRS can excuse some of them. A group asked to be relieved from that duty. This letter is the IRS's…
IRS confirms a church-affiliated school need not file Form 990, but must still certify nondiscrimination
A below-college-level school affiliated with a church asked to be excused from filing the yearly Form 990 information return. This letter is the IRS's favorable determination. Under Treasury…
IRS confirms a governmental-unit affiliate need not file Form 990
Tax-exempt organizations generally must file a yearly Form 990 information return, but the IRS can excuse some of them. A group asked to be relieved from that duty. This letter is the IRS's…
IRS denies § 501(c)(3) exemption to an office healthy-snack sale
A group applied (using the short Form 1023-EZ) to be recognized as a tax-exempt charity under IRC § 501(c)(3). Its only activity was running a healthy-snack stand in an office, selling snacks to…
IRS denies 501(c)(7) social-club exemption to a group that funds a baseball team's players
An organization applied to be recognized as a tax-exempt social club under IRC § 501(c)(7), the category for clubs run for the pleasure and recreation of their members. The IRS denied it. The group…
IRS revokes a charity's 501(c)(3) exemption for going inactive and ignoring an audit
The IRS revoked an organization's tax-exempt status under IRC § 501(c)(3). The group had been recognized as a charity after filing a streamlined Form 1023-EZ application, but it later stopped filing…
IRS revokes a social club's 501(c)(7) exemption for excessive rental and billboard income
The IRS revoked a social club's tax-exempt status under IRC § 501(c)(7). Social clubs, like this cultural-gathering organization, get their exemption only if they run substantially on member dues…
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.