Quality Auditing Company, Inc. - Page 18




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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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