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compensation payments have exceeded $13 billion in each
of the last seven years, and in 1993--even as recovery
set in--states paid out nearly $22 billion in regular
unemployment benefits. Federal spending on
administrative costs for regular unemployment insurance
totalled $2.5 billion last year. But unemployment
insurance is not designed to help speed workers into
reemployment. So despite these huge outlays, the
predicament of the long-term unemployed led to the
repeated provisions of federal Emergency Unemployment
Compensation payments, costing $24 billion over the
past two years. [Reemployment Initiative: Hearings on
S. 1951 (Reemployment Act of 1994) Before the Senate
Comm. on Finance, 103d Cong., 2d Sess. (May 26, 1994)
(statement of Robert B. Reich, Secretary of Labor);
emphasis added.]
The activities of petitioner fall outside of the definition
of “charitable” under section 501(c)(3). Petitioner trains
individuals to fill temporary positions as secretaries, word
processors, desktop publishers, data entry operators, general
clerical workers, receptionists, and light industrial laborers.
Petitioner also assists clients in finding a chain of temporary
jobs so that a client will have employment year-round.
Petitioner encourages clients to create an independent contractor
relationship with temporary employers by using a limited
liability company to market the services of the client. The act
of creating a limited liability company might also prevent a
client from being labeled as an employee of petitioner. These
activities are indistinguishable from the activities of a for-
profit temporary service agency.
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