Quality Auditing Company, Inc. - Page 13




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          organized and operated exclusively for exempt purposes, not                 
          benefiting private interests more than incidentally.  See Rule              
          217(c)(4)(A); Redlands Surgical Servs. v. Commissioner, supra at            
          72; American Campaign Academy v. Commissioner, supra at 1063-               
          1064.                                                                       
          II.  Contentions of the Parties                                             
               Petitioner contends that it satisfies the requirements of              
          section 501(c)(3) for exemption from Federal taxation as a                  
          charitable organization.  Petitioner maintains that it is                   
          organized and operated exclusively for charitable purposes, that            
          no part of its net earnings inures to the benefit of private                
          individuals, and that it serves public rather than private                  
          interests.  According to petitioner, its purpose and activities             
          qualify as charitable in that quality auditing of steel                     
          fabrication firms both lessens the burdens of Government and                
          encourages the safe construction of buildings and bridges for the           
          benefit of the general public.                                              
               Conversely, respondent asserts that petitioner is not                  
          entitled to exemption from taxation under sections 501(a) and               
          (c)(3).  Respondent concedes that petitioner is organized                   
          exclusively for exempt purposes and that no part of its net                 
          earnings inures to the benefit of proscribed private individuals.           
          However, it is respondent’s position that petitioner’s inspection           
          activity neither lessens the burdens of Government nor confers              






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Last modified: May 25, 2011