Maricopa County v. Novasic
In Maricopa County v. Novasic, 12 Ariz. App. 551, 553, 473 P.2d 476, 478 (1970), the Court stated that an exception exists: the parties can abrogate the general rule that the lessor owns improvements built by the lessee by expressly agreeing to treat the improvements as belonging to the lessee. 12 Ariz. App. at 553, 473 P.2d at 478;
See also 25 C.F.R. 162.608 (2008) ("Improvements placed on the leased land shall become the property of the lessor unless specifically excepted therefrom under the terms of the lease.").