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incidental to the services offered. Id. The facts in our case
are more akin to those services offered by a hospital or school,
where the prime concern of the tenants is the receipt of
services, whether medical, teaching, or, in our case, legal.
While the space leased may have factored into the attorney-
tenants’ determination, it was incidental to the services they
received.
AGI provided substantial support services to its tenants,
and AGI’s tenants leased space exclusively so that they would
have the benefit of those services. Specifically, AGI provided
its attorney-tenants with a paralegal, a legal intern, a law
clerk, an up-to-date law library, a computer with legal research
capabilities, and two conference rooms.9 AGI’s employees
performed client intake, answered phones, took messages, filed
documents at the courthouse and State capitol, typed briefs, took
dictation, referred cases, scheduled depositions and court
reporters, arranged travel, managed a file room and file storage,
and performed legal research. AGI also offered petitioner
husband’s expert consulting services, as well as referrals for
medical-related cases.
Witnesses for petitioners testified that AGI’s services to
its tenants were unique in the area close to the courthouse, and
that they would not have moved onto the premises if the support
services were not provided. We find of particular significance
that AGI performed legal research for its attorney-tenants.
9After the years at issue, AGI also provided tenants with
video-conferencing equipment.
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