Quality Auditing Company, Inc. - Page 19




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               501(c)(3).  One need only glance at the other types of                 
               organizations described in section 501(c) for examples                 
               of “nonpublic” organizations which often do much to                    
               enhance the public good * * *                                          
                    We think it is significant that Congress enacted                  
               special exemption provisions for certain types of                      
               organizations which would be unable to meet the                        
               stricter section 501(c)(3) tests which require service                 
               to public interests rather than to private ones. * * *                 
               [American Campaign Academy v. Commissioner, 92 T.C.                    
               1053, 1077-1078 (1989).]                                               
               Here, the development and administration of a quality                  
          certification program, at the request of and for the structural             
          steel industry, would appear to be consistent with AISC’s mission           
          as a section 501(c)(6) organization.  AISC, in its solicitations            
          to owners and developers, states that the program is “intended to           
          make the task of selecting qualified bidders more reliable” and             
          “exists to provide assurances to construction team members such             
          as yourself that suppliers are capable of performing according to           
          your specification.”  The focus thus seems to be on aiding                  
          industry participants, with any benefit to the general public               
          being merely secondary.  We note that safety is never mentioned             
          in the solicitation, and having qualified bidders and suppliers             
          would address a host of concerns distinct from that of ending up            
          with a finished product that will not harm its users.  Increased            
          nonconformities, delays, project cost overruns, reduced structure           
          longevity, and frequent repair expenditures are among the                   
          problems that could flow from hiring fabricators with inadequate            







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