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FAMILY TRUST OF MASSACHUSETTS, INC. v. U.S.

No. 12-5360.

722 F.3d 355 (2013)

FAMILY TRUST OF MASSACHUSETTS, INC., Appellant v. UNITED STATES of America, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided June 28, 2013.

Attorney(s) appearing for the Case

Christopher S. Rizek argued the cause for the appellant. Matthew C. Hicks was on brief.

Jennifer M. Rubin , Attorney, United States Department of Justice, argued the cause for the appellee. Ronald C. Machen Jr. , United States Attorney, and Kenneth L. Greene , Attorney, were on brief.

Before: HENDERSON, TATEL and GRIFFITH, Circuit Judges.

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...

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