Quality Auditing Company, Inc. - Page 14




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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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