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likewise bereft of evidence that, in absence of the AISC program,
governmental entities would have undertaken to develop a similar
program or to conduct actual audit inspections.
Furthermore, to the extent that the existence of the AISC
program and petitioner’s role therein facilitate the Government
in selecting qualified fabricators, an equivalent benefit is
conferred upon private owners and developers. Private entities
joined with public in requesting the AISC program and likewise
utilize the program in awarding bids. If, as petitioner
contends, it is operated to lessen the burdens of Government, it
would follow that it is also operated to lessen the burdens on
private parties. While the former is a charitable purpose, the
latter is not, and the record offers no basis upon which to
determine that the latter is merely incidental to the former. We
thus cannot conclude that petitioner is operating exclusively for
the charitable purpose of lessening the burdens of Government.
B. Encouraging Safe Construction
We turn to the question of whether petitioner is operating
exclusively for the charitable purpose of encouraging safe
construction for the benefit of the general public. We
acknowledge that furthering public safety is indeed a charitable
objective. Moreover, we do not dispute that the AISC
certification program and petitioner’s audit activities promote
increased structural integrity and safety in steel buildings and
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