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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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