Quality Auditing Co. v. Commissioner
United States Tax Court
P is a nonprofit corporation organized to audit structural steel fabricators pursuant to a quality certification program administered by the American Institute of Steel Construction, Inc. (AISC). AISC is likewise a nonprofit organization and is exempt from Federal taxation under sec. 501(c)(6), I.R.C. As its primary activity, P inspects the quality control procedures used in facilities of fabricators applying to AISC for certification.
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P is a nonprofit corporation organized to audit structural steel fabricators pursuant to a quality certification program administered by the American Institute of Steel Construction, Inc. (AISC). AISC is likewise a nonprofit organization and is exempt from Federal taxation under sec. 501(c)(6), I.R.C. As its primary activity, P inspects the quality control procedures used in facilities of fabricators applying to AISC for certification. P evaluates whether such procedures are in compliance with the standards set forth in the AISC program. The certification program was established by AISC at…
1Opinion of the Court
OPINION
Nims, Judge:
Respondent determined that petitioner Quality Auditing Co., Inc., does not qualify for exemption from Federal income taxation under section 501(a) as an organization meeting the requirements of section 501(c)(3). Having exhausted its administrative remedies, petitioner challenged respondent’s determination by timely invoking the jurisdiction of this Court for a declaratory judgment pursuant to section 7428(a). The case was submitted for decision under Rule 122 upon the stipulated administrative record. For purposes of this proceeding, the facts and representations contained…
2Cases cited11 opinions
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Church in Boston v. CommissionerUnited States Tax Court · 1978
- Copyright Clearance Center, Inc. v. CommissionerUnited States Tax Court · 1982
- American Campaign Academy v. CommissionerUnited States Tax Court · 1989
- Nationalist Movement v. CommissionerCourt of Appeals for the Fifth Circuit · 1994
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3Cited by4 opinions
- Jamerson v. COLEMAN-ADAMS CONST., INC.Supreme Court of Virginia · 2010
- Abovo Foundation, Inc. v. CommissionerUnited States Tax Court · 2018
- Quality Auditing Co. v. CommissionerUnited States Tax Court · 2000
- Quality Auditing Company, Inc. v. CommissionerUnited States Tax Court · 2000