Quality Auditing Company, Inc. - Page 20




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          quality control.  Therefore, to the extent that petitioner serves           
          AISC’s interests in carrying out its section 501(c)(6) role of              
          industry betterment, petitioner benefits a private interest.                
               The steel fabricators who request audits and whose                     
          facilities petitioner inspects are likewise private entities.               
          Moreover, because these fabricators operate as commercial                   
          enterprises, we are constrained to assume that they largely apply           
          for certification when to do so furthers their primary objective            
          of making a profit.  We doubt that firms would seek and pay to              
          obtain certified status unless they believed the investment would           
          prove lucrative in the future.  They likely wish to pursue                  
          revenues from a contract requiring certification, or they see the           
          certification process as a vehicle to increased work through an             
          improved control process and reputation for quality.  Thus, in              
          auditing these fabricators, petitioner is once again furthering             
          private interests.                                                          
               Lastly, petitioner has failed to convince us that the                  
          private interests discussed above are insubstantial in comparison           
          to the benefit reaped by the general public.  The majority of               
          steel structures built in the United States do not require                  
          certified fabricators.  The certification process itself does not           
          result in petitioner’s inspecting or certifying the safety of any           
          finished structure or product with which the public might come in           
          contract.  Rather, petitioner evaluates the internal quality                






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Last modified: May 25, 2011