Quality Auditing Company, Inc. - Page 9




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               The Cleveland stadium is a highly complex and visible                  
               project.  We recommend the following language be                       
               inserted n [sic] your structural steel specification:                  
                    “The structural steel fabricator shall be                         
                    certified at the time of bid in the AISC                          
                    Quality Certification Program in the Complex                      
                    Steel Structure Category with a Sophisticated                     
                    Paint Endorsement.  A copy of the certificate                     
                    shall be submitted with the bid documents.”                       
               If you’d like more information on the Certification                    
               Program, please feel free to call * * *                                
               Petitioner’s application for exemption under section                   
          501(c)(3), for its role in the above-described quality                      
          certification endeavor, was received by the Internal Revenue                
          Service on August 2, 1995.  On February 11, 1999, respondent                
          issued the final adverse ruling which is the subject of this                
          litigation.                                                                 
                                     Discussion                                       
          I.  General Rules                                                           
               Section 501(a) exempts from Federal income taxation                    
          organizations described in section 501(c).  Among the                       
          organizations so described are those set forth in section                   
          501(c)(3):                                                                  
                    Corporations * * * organized and operated                         
               exclusively for religious, charitable, scientific,                     
               testing for public safety, literary, or educational                    
               purposes, or to foster national or international                       
               amateur sports competition * * * , or for the                          
               prevention of cruelty to children or animals, no part                  
               of the net earnings of which inures to the benefit of                  
               any private shareholder or individual * * *                            







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Last modified: May 25, 2011