Quality Auditing Company, Inc. - Page 16




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          audits of steel fabricators.  Yet there is no indication in the             
          record that governmental units consider it their burden to                  
          inspect or certify the quality control procedures in place in the           
          facilities of private fabricators.  The quality inspection and              
          certification activities here are not part of a legislated                  
          governmental program, are not the result of an express                      
          governmental delegation of function, and do not seek to enforce             
          governmentally established standards or guidelines.  See Indiana            
          Crop Improvement Association v. Commissioner, 76 T.C. 394 (1981)            
          (relying on such factors to hold that a taxpayer’s testing and              
          certification of agricultural products lessened the burdens of              
          Government); see also Professional Standards Review Org. v.                 
          Commissioner, 74 T.C. 240 (1980) (finding an entity authorized by           
          statute to review utilization of Government-subsidized programs             
          to lessen the burdens of Government).                                       
               Rather, the record reflects only that governmental agencies            
          were among those who initially requested that AISC develop a                
          certification program and who have since made use of the program            
          in awarding bids.  Although such involvement shows a concern with           
          obtaining high-quality steel work in public projects, it falls              
          short of demonstrating that governmental units view a program for           
          auditing steel fabricators as a Government responsibility and               
          recognize petitioner as acting on their behalf.  The record is              








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