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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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