Quality Auditing Company, Inc. - Page 21

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          control procedures of private, for-profit steel fabricators,                
          incident to a quality certification program administered by a               
          nonpublic section 501(c)(6) entity and implemented at the request           
          of steel industry participants.  Accordingly, we conclude that              
          petitioner is operated to a substantial degree for the benefit of           
          private interests, including those of AISC and members of the               
          steel industry.  As furthering private interests constitutes a              
          nonexempt purpose, petitioner has not established that it is                
          operated exclusively for exempt charitable purposes.  We hold               
          that petitioner is not entitled to exemption from taxation as a             
          charitable organization described in section 501(c)(3).                     
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             for respondent.                          

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