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In the early 1980's, the Company hired Dr. Sherry Manning as
its new chief executive officer. Prior to being hired by the
Company, Dr. Manning had been the president of Colorado Women's
College. Dr. Manning told petitioner's daughter that GMC could
charge the Museum for the services it provided to the Museum, so
long as the charge was not higher than the fair market rate for
the services rendered. As indicated above, GMC began charging
the Museum for the services that it provided in connection with
the special events.
Greenwood Maintenance Co.
Petitioner owns a 75-percent stake in GMC, a maintenance and
janitorial company. Thus, GMC is defined as a disqualified
person under section 4946(a)(1) with respect to the Museum.
During the years at issue, GMC performed maintenance
functions for approximately 20 of the buildings in Greenwood
Plaza, including all of the buildings owned by the Company.
Throughout the years at issue, the Museum contracted with GMC to
perform janitorial and related services. Depending on the job
requirements, GMC would either perform the work itself or sub-
contract with third parties to have the work performed.
Fiddler's Green Amphitheatre
On August 26, 1986, Greenwood Plaza South, a partnership in
which petitioner was a partner, donated FGA to the Museum. Con-
current with the FGA donation, a 3-acre park contiguous to the
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