Management Company's Labor Costs Improperly Excluded from MCI

Landlord applied for MCI rent hikes based on the building-wide installation of new windows. The DRA ruled for landlord in part but disallowed any increase for labor costs because the work was performed by the company that managed the building. Landlord appealed and won. The management company wasn't affiliated with the building owner, and the fact that it served as contractor didn't necessarily require exclusion of the labor costs. There was no proof that the installation was performed by landlord's employees as part of their regular duties. 

514 48th Street: DHCR Adm. Rev. Docket No. WH210013RO (6/26/13) [1-pg. doc.]