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University Med. Resident Servs., P.C. v. Commissioner, T.C. Memo.
1996-251; Public Indus., Inc. v. Commissioner, T.C. Memo. 1991-3.
First, the activities engaged in by the organization must be
those which a governmental unit considers to be its burden. See
Columbia Park & Recreation Association v. Commissioner, supra at
21 & n.45; University Med. Resident Servs., P.C. v. Commissioner,
supra; Public Indus., Inc. v. Commissioner, supra. In other
words, it must be shown that a governmental unit accepts as its
responsibility the activities conducted by the organization and
recognizes the organization as acting on the Government’s behalf.
See Columbia Park & Recreation Association v. Commissioner, supra
at 21. Second, the organization’s performance of the activities
must actually lessen the burdens of Government. See Columbia
Park & Recreation Association v. Commissioner, supra at 21 &
n.45; University Med. Resident Servs., P.C. v. Commissioner,
supra; Public Indus., Inc. v. Commissioner, supra. However, “The
mere fact that such activities might improve the general economic
well-being of the Nation or a State or reduce any adverse impact
from the failure of Government to carry out such activities is
not enough.” Public Indus., Inc. v. Commissioner, supra.
Applying these criteria to the case at bar, we conclude that
petitioner has failed to make the requisite showing for an
exemption on the basis of lessening Government burdens.
Petitioner’s primary activity consists of performing quality
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