Private Letter Ruling
Articles related to tax regulations and how they impact taxpayers.
Organization's Exempt Status Revoked
March 21, 2025
Organization previously applied for tax exempt status as a church under IRC section 501(c)(3). Organization’s primary purpose, as stated in...
Community Association Denied Tax-Exempt Status
March 14, 2025
Organization applied for tax exempt status under Sec. 501(c)(3). Organization’s primary purpose as a business association is to support local...
Employer-Related Scholarship Procedures Approved
March 7, 2025
Foundation requested advance approval of its employer-related scholarship procedures under Sec. 4945(g)(1). Approval is requested for a scholarship program for...
Tax-Exempt Status Denied for Software Promoter
February 28, 2025
Organization applied for tax exempt status under Sec. 501(c)(6). Organization’s mission is to promote another organization’s blockchain ecosystem open-source software...
Portability Election Extension Not Granted
February 21, 2025
Decedent passed away and was survived by Spouse. Under Sec. 6018(a), Decedent’s estate (Estate) was not required to file Form...
Tax-Exempt Status Denied for Union Organization
February 14, 2025
Union Organization (Organization) applied for tax exempt status under Sec. 501(c)(3). Its articles state that it is an association of...
Foundation Granted Additional Time to Sell Excess Business Holdings
February 7, 2025
Organization is tax-exempt under Sec. 501(a), as an organization described in Sec. 501(c)(3) and classified as a private foundation under...
NIL Nonprofit Denied Exempt Status
January 31, 2025
Organization applied for exempt status under Sec. 501(c)(3). Organization states that it is a nonprofit corporation whose purpose is to...
Extension for Portability Election Granted
January 24, 2025
Decedent passed away and was survived by Spouse. Under Sec. 6018(a), Decedent’s estate (Estate) was not required to file Form...
Foundation's Set-Aside Approved
January 17, 2025
Foundation is tax-exempt under Sec. 501(c)(3) and a private foundation under Sec. 509(a). Since its formation, Foundation has provided grants...
Extension for QTIP Election Granted
January 10, 2025
Decedent executed a revocable trust (Trust). Decedent died and was survived by Spouse. Upon Decedent’s death, the terms of Trust...
Farmer's Market Denied Exemption
January 3, 2025
Organization applied for tax exempt status under Sec. 501(c)(3). Organization’s primary purpose is to have a marketplace in which local...
LLC Activities Qualify as Charitable and Educational Under 501(c)(3)
December 27, 2024
Taxpayer is a nonprofit corporation (Taxpayer) under section 501(c)(3) and classified as a public charity under sections 509(a)(1) and 170(b)(1)(A)(vi)...
Amendment to CRUT Terms is Approved
December 20, 2024
A and B executed a trust (Trust) that intended to qualify as a charitable remainder unitrust under Sec. 664(d)(2). The...
Extension for Portability Election Granted
December 13, 2024
Decedent passed away and was survived by Spouse. Under Sec. 6018(a), Decedent’s estate (Estate) was not required to file Form...
Business Group Denied Tax-Exempt Status
December 6, 2024
Organization applied for tax exempt status under Sec. 501(c)(3). Organization’s primary purpose as a business association is to support local...
Educational Grant Procedures Approved
November 29, 2024
Foundation requested advance approval of its educational grant procedures. The grant program’s purpose is to help support entrepreneurs by providing...
Tax-Exempt Status Denied for Dog Training Group
November 22, 2024
Organization applied for exempt status under Sec. 501(c)(3). Organization states that it is organized for the training of dogs and...
Reverse QTIP Election Extension Granted
November 15, 2024
Decedent established a revocable trust (Trust) and was survived by Spouse. Under the terms of Decedent’s Trust, the trustee divided...
Cemetery Operator Denied Tax Exemption
November 8, 2024
Organization applied for exempt status under Sec. 501(c)(3). Organization states that it is organized and operated to provide the sale...