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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