114 T.C. No. 31
UNITED STATES TAX COURT
QUALITY AUDITING COMPANY, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8794-99X. Filed June 19, 2000.
P is a nonprofit corporation organized to audit
structural steel fabricators pursuant to a quality
certification program administered by the American Institute
of Steel Construction, Inc. (AISC). AISC is likewise a
nonprofit organization and is exempt from Federal taxation
under sec. 501(c)(6), I.R.C. As its primary activity, P
inspects the quality control procedures used in facilities
of fabricators applying to AISC for certification. P
evaluates whether such procedures are in compliance with the
standards set forth in the AISC program. The certification
program was established by AISC at the request of public and
private owners and developers who desired a reliable method
for selecting competent fabricators from among those who
submit bids for the steel work component of a construction
project.
P seeks tax-exempt status as an organization described
in sec. 501(c)(3), I.R.C., on the grounds that P is operated
exclusively for the charitable purposes of lessening the
burdens of Government and encouraging safe construction for
the benefit of the general public.
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