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bridges. Nonetheless, we find that petitioner’s activities also
further private interests to a degree that is more than
insubstantial. See Better Bus. Bureau v. United States, 326 U.S.
279, 283 (1945).
Petitioner performs quality audits at the request of AISC,
which in turn acts at the request of steel fabricators applying
for certification. Neither AISC nor the fabricators, however,
are public entities. As an organization exempt from taxation
under section 501(c)(6), AISC is a business league or board of
trade. Such entities are defined as follows:
A business league is an association of persons
having some common business interest, the purpose of
which is to promote such common interest and not to
engage in a regular business of a kind ordinarily
carried on for profit. It is an organization of the
same general class as a chamber of commerce or board of
trade. Thus, its activities should be directed to the
improvement of business conditions of one or more lines
of business * * * [Sec. 1.501(c)(6)-1, Income Tax
Regs.]
Hence, AISC is classified as an organization which seeks the
betterment of an industry, not the betterment of the general
public. Although AISC’s actions are not profit-motivated and may
have positive results for society at large, that does not
transform AISC’s purpose, and activities undertaken in
furtherance thereof, from private to public. As expressed by
this Court:
It is clear, however, that not all organizations which
incidentally enhance the public good will be classified
as “public” organizations within the meaning of section
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