A pooled special needs trust formed by a Massachusetts attorney to allow elderly and disabled persons to receive benefits that supplement, rather than replace, governmental benefits has been denied 501(c)(3) charitable tax exemption in a declaratory judgment action brought by the attorney against the IRS. The federal District Court for the District of Columbia has ruled that the applicant did not sufficiently show that the entity was operated solely for charitable purposes and that its net earnings do not provide private inurement to the founder. Peter Macy, an attorney who specializes in elder law, formed the Family Trust of Massachusetts, Inc. and first filed for exemption in 2005. He...