Quality Auditing Company, Inc. - Page 1

                                   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             
                    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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