Family Trust of Massachusetts, Inc. v. United States
Court of Appeals for the D.C. Circuit
1Opinion of the Court
KAREN LECRAFT HENDERSON, Circuit Judge:
The Family Trust of Massachusetts, Inc. (FTM) manages a pooled trust established pursuant to 42 U.S.C. § 1396p(d) to provide supplemental services and benefits to disabled individuals receiving Medicaid, Supplemental Security Income (SSI) or other public benefits. FTM applied to the United States Internal Revenue Service (IRS) for a charitable tax exemption under I.R.C. § 501(a) and (c)(3) based on its trustee services. After the IRS preliminarily denied FTM’s application, FTM filed this action seeking a declaration that it is a tax exempt charitable…
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