- 13 - 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 confersPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011