- 9 - 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 * * *Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011