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The Museum contends that the arrangement with Budweiser did
not amount to a sublease, and therefore the proceeds from the
event do not taint the remaining rental income under the Second
Lease. The Museum misconstrues respondent's argument. The
Museum's contention is premised on the belief that respondent is
assailing the arrangement with MCA based upon section 1.856-
4(b)(6), Income Tax Regs. That regulation covers situations
involving a lease based, at least in part, on the gross receipts
of the lessee, where the lessee has subleased the property to a
sublessee. There, the rent being calculated under the sublease
is based upon the profits of the sublessee. Respondent's
position, however, is premised on the fact that the lease
proceeds the Museum collects are based on the profits of MCA, and
respondent's argument has nothing to do with the labels attached
to MCA's arrangement with Budweiser. Thus, the Museum's attempt
to distinguish its situation from section 1.856-4(b)(6), Income
Tax Regs., fails to address respondent's contentions. We
therefore sustain respondent's determination that the rent
received in 1988 from the lease with MCA is subject to UBIT.
Issue 3. Payments to GMC
Section 4941 imposes an excise tax for acts of "self-
dealing" that occur between a private foundation and a "disquali-
fied person". Sec. 4941(a)(1). The parties agree that GMC is a
"disqualified person" with respect to the Museum, a private
foundation. For the purposes of this section, "self-dealing"
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