John W. Madden, Jr., et al. - Page 18

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          services, whereas the cleaning of public areas and the collection           
          of trash are not considered to be services rendered primarily for           
          the convenience of the tenant.  Id.                                         
               Typically, a complex such as FGA is built with parking areas           
          surrounding the structure.  Any lease of the building necessarily           
          contemplates that the lessee will be able to use the surrounding            
          parking spaces.  Here, the Museum was required to undertake                 
          unique measures in order to provide the parking necessary for MCA           
          to use FGA.  These arrangements were necessary to put FGA on                
          equal footing with similar complexes and do not represent                   
          impermissible services under the regulation.  The evidence at               
          trial indicates that, once the spaces were made available, MCA              
          took on the primary responsibility of managing the parking spaces           
          during the concerts, although the Museum retained some respon-              
          sibility for security and cleanup.  In effect, instead of                   
          building a parking garage, the Museum created parking spaces                
          through these license arrangements.  Once the arrangements were             
          complete, however, the Museum turned over the primary operating             
          duties to MCA for the duration of the concerts.  These arrange-             
          ments do not constitute impermissible services.                             
               Respondent also argues that the maintenance and security               
          services furnished by the Museum are impermissible services                 
          provided to the tenant.  The Second Lease requires the Museum to            
          maintain or provide for the maintenance of all existing struc-              
          tures at the outset of the Second Lease and to arrange for                  




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