The rest of Dish’s winning bids — worth about $5.5 billion — were done under a partnership with John Muleta, the former chief of the F.C.C.’s wireless telecommunications bureau, and relied on similar loopholes. As a former government official, Mr. Muleta has no real revenue and so meets the test of being a “very small business.”

No doubt Dish and its lawyers are high-fiving one another and patting themselves on the back. By giving 15 percent ownership to Doyon at a discounted price, they have saved themselves billions.

Taxpayers, however, may want to ponder what those billions of dollars could have done in the coffers of the government — a new bridge or money for schools, perhaps.

And this is not a new issue. The “small firm” exemption has been known to be a problem at the F.C.C. for years. The Congressional Budget Office in 2005 wrote a report highlighting how it was used mostly by big companies instead of the small firms it was intended to benefit. Moreover, the office found that the program provided little benefit to consumers while providing a big discount to companies. In a 2006 auction, AT&T successfully used this structure with Doyon.

The latest spectrum auction — and the attention it has received — may finally push the F.C.C. to eliminate this exemption. It’s hard to see how it benefits anyone but Dish and Doyon, which both get free money for not doing much of anything.

More immediately, the agency should take a good, hard look at the structure of the arrangement.

Doyon has control over Northstar in its day-to-day operations, but the agreements also require Northstar to be managed according to a five-year business plan agreed to by Dish in advance. No deviation in any material respect can be made without Dish’s approval through a subsidiary. Not only that, but there is a multipage list of things that Northstar cannot do without approval from Dish’s subsidiary. These restrictions include spending more than $2 million, selling the company or paying any executive more than $200,000.

Given Dish’s significant control and the requirement that Doyon cannot deviate from a previously agreed business plan, Dish is having its discount but still getting effective control. Though the F.C.C. may have passed on this issue without scrutiny before, this instance would seem to provide grounds to challenge the exemption claim.