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upon the general public any benefit which is not merely
incidental to petitioner’s furthering of the private interests of
AISC and firms within the steel industry.
We conclude, for the reasons explained below, that
petitioner has failed to establish that it qualifies for
exemption from tax as a charitable organization within the
meaning of section 501(c)(3).
III. Application
The question of whether petitioner is entitled to tax-exempt
status as a section 501(c)(3) organization turns here upon
whether petitioner is operated exclusively for exempt purposes.
Petitioner’s primary activity consists of performing audits of
steel fabricators who have applied to AISC for quality
certification. Petitioner contends that, in so functioning, it
operates exclusively for the charitable purposes of lessening the
burdens of Government and encouraging safe construction for the
benefit of the general public. We examine each of these
potential grounds for exemption.
A. Lessening the Burdens of Government
An organization can be classified as having the charitable
purpose of lessening the burdens of government only if two
criteria are satisfied. See Columbia Park & Recreation
Association v. Commissioner, 88 T.C. 1, 21 & n.45 (1987), affd.
without published opinion 838 F.2d 465 (4th Cir. 1988);
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