In Priv. Ltr. Rul. 200621025 (3/2/06, released 5/26/06), the Service denied § 501(c)(3) status to an organization providing consulting and managerial services to disabled persons who are beneficiaries of special needs trusts and to the families of these individuals. The Service ruled that the organization will provide benefits to specific persons (the beneficiaries and their families), rather than to an indefinite class of individuals. The Service also rejected the application on the grounds of private inurement and operation of a trade or business in a commercial manner.




