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admin — Wed, 22 Feb 2012 07:32:58 +0000

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Structural Steel Fabricators Citation …

admin — Tue, 21 Feb 2012 07:24:23 +0000

Citation: 114 T.C. 498 (2000) Introduction to the Case The U.S. Tax Court held that a nonprofit organization that audits Structural Steel Fabricators in conjunction with a quality certification program conducted by a related trade association does not constitute a charitable organization that lessens the burdens of government, and yields private benefit to the association and to the fabricators who are inspected. This is the first case in which the private benefit doctrine was applied with respect to a benefit conferred on a tax-exempt, noncharitable organization. Facts Developments and concerns within the structural steel fabrication industry, and particularly the response to them by the American Institute of Steel Construction, Inc. (AISC), led to the formation of Quality Auditing Company (QAC). QAC was organized as a nonprofit charitable and educational entity. AISC, a tax-exempt business league, has been engaged primarily in the creation of standardized engineering codes and specifications for use in the fabrication and construction of steel-framed buildings and bridges. During the 1960′s, a number of governmental agencies and private industrial owners and developers approached AISC and requested that it develop a certification program for Structural Steel Fabricators. Technological advances had increased both the predominance and the complexity of steel’s role in commercial and residential structures; a growing concern over potential differences in quality had arisen among entities attempting to select contractors for this component of a building project. Yet few owners and developers had sufficient expertise, time, or funds to adequately investigate the fabricators submitting project bids. AISC undertook to create a program that would afford the requested quality assurances. Working in collaboration with engineers, architects, contractors, and other industry participants (including government agencies), AISC developed and trademarked the AISC Quality Certification Program (Program). The Program incorporates codes, standards, and specifications for particular aspects of the fabricating process. It is designed to verify that fabricators have in place a quality control system that will assure compliance with construction standards and contract requirements. Ongoing revision and upgrading of the Program track changes and advancements within the industry. Fabricators desiring certification, often because the owner or developer of a project conditioned bid awards on that requirement, submit an application and appropriate fee to AISC. The fees are determined in accordance with a schedule set by AISC and are based on the fabricator’s status as a member or nonmember of AISC, the type of certification being sought, and the number of employees at the facility. The Program is open to all fabricators, regardless of AISC membership. AISC then contracts with and pays for an independent entity to perform the actual audit investigation of the fabricator’s facility. The auditor evaluates the fabricator’s quality control procedures to determine whether the procedures adequately test for and ensure compliance with the industry specifications incorporated in the Program. No particular structure, project, or product is certified; the construction process itself is examined. Following the audit, the auditor communicates the findings to the fabricator and recommends to AISC whether certification should be awarded. Upon receipt of a positive recommendation from the auditor, AISC forwards to the fabricator documentation reflecting AISC certified status. If the auditor does not believe certification is warranted, the fabricator may choose to be reevaluated after corrective actions have been implemented. The specific report pertaining to a particular audit is not disseminated to the public, although AISC publishes the names of the certified companies. In administering the Program, AISC initially contracted with a for-profit company to conduct the facility audits. This approach was not successful, however, in that (in the words of the court) a “profit-driven enterprise was unwilling to reinvest a sufficient portion of the fees charged to achieve the level of auditor training and audit consistency necessary for a uniform, reliable certification program.” Consequently, AISC provided the startup capital to establish QAC as a nonprofit corporation. Its purpose is to conduct quality certification and inspection programs that meet the requirements of private and public standards-setting bodies and governmental agencies. No other organization presently provides this service. The boards of directors of AISC and QAC are overlapping. QAC hires and trains independent contractors to inspect and audit the facilities of fabricators applying to AISC for certification. IT pays royalties to AISC for use of its trademarked certification program. QAC’s income is derived solely from the fees charged AISC for conducting the quality audits. Fees are set at a level that approximates actual costs. The AISC certification program is increasingly becoming recognized as furthering structural integrity and quality within the steel fabrication industry. Numerous private and public owners, developers, and contractors (including the Army Corps of Engineers and as many as 40 state highway departments) require AISC certification for bridges and other metal work. To promote the Program, AISC solicits owners and developers to require certification of fabricators submitting bids. The IRS ruled that AISC was not entitled to recognition of tax-exempt status as a charitable entity. Summary of Opinion QAC asserted that its purpose and activities are charitable in that quality auditing of steel fabrication firms lessens the burdens of government and encourages the safe construction of buildings and bridges for the benefit of the general public. The IRS’s view was that QAC’s inspection activity does not lessen the burdens of any government and does not confer upon the public any benefit which is not merely incidental to QAC’s furthering of the private interests of AISC and firms within the steel industry. Lessening the burdens of government is one way for a nonprofit organization to be charitable for federal income tax exemption purposes. Generally, however, two criteria must be satisfied. One is that the activities engaged in by the organization must be those that a governmental unit considers to be its burden. The other is that the organization’s performance of the activities must actually lessen the burdens of a government. QAC failed the first of these tests. The court observed that there is no indication in the record that governmental units consider it their burden to inspect or certify the quality control procedures in place in the facilities of private fabricators. It was noted that governmental agencies were among those who initially requested that AISC develop a certification program and who have since made use of the Program in awarding bids. But, wrote the court, these facts “fall short of demonstrating that governmental units view a program for auditing steel fabricators as a Government responsibility and recognize [QAC] as acting on their behalf.” The court added that, to the extent that QAC facilitates government in selecting qualified fabricators, an equivalent benefit is conferred on private owners and developers. Private entities joined with public ones in requesting the AISC program and likewise utilize the Program in awarding bids. The court concluded that, if QAC is operated to lessen the burdens of government, it also operates to lessen the burdens on private parties. The court wrote that “furthering public safety is indeed a charitable objective.” It agreed that the certification program and QAC’s audit activities promote increased structural integrity and safety in steel buildings and bridges. Nonetheless, it concluded that QAC’s activities also further private interests to a degree that is more than insubstantial. The court reiterated that QAC performs quality audits at the request of AISC, which in turn acts at the request of steel fabricators applying for certification. The association and the fabricators are not, however, public entities. It was written that 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 business league. The court added that the “focus thus seems to be on aiding industry participants, with any benefit to the general public being merely secondary.” The court thus saw more than insubstantial private benefit in two contexts. One was the extent to which QAC serves AISC’s interests in carrying out its role of industry betterment. QAC’s efforts prevent problems in the industry that could flow from hiring fabricators with inadequate quality control, such as increased nonconformities, delays, project cost overruns, reduced structure longevity, and frequent repair expenditures. The court noted that safety is never mentioned in the solicitations of owners and developers. The other type of private benefit is that accruing to the steel fabricators who request audits and whose facilities are inspected by QAC. These are commercial entities, and the court was “constrained to assume” that they largely apply for certification when to do so furthers their primary objective of making a profit. The fabricators “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.” Both types of private benefit were found to be substantial, notwithstanding some “benefit reaped by the general public.” Commentary A commentary on this court opinion appears in the September 2000 issue of The Nonprofit Counsel. Background Information A summary of the law underlying this court opinion is in sections 6.3 and 19.10 of The Law of Tax-Exempt Organizations, Seventh Edition.

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admin — Mon, 20 Feb 2012 07:16:15 +0000

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admin — Sun, 19 Feb 2012 07:08:38 +0000

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admin — Sat, 18 Feb 2012 07:01:56 +0000

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admin — Wed, 15 Feb 2012 07:26:23 +0000

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Fleet Management Systems Insights …

admin — Sun, 12 Feb 2012 07:08:11 +0000

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