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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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