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I had mine done about 2mo ago, Ray Catena in NJ told me any time the car comes in for a recall, they fill the tank (regardless of the fact they had to drop the fuel tank to do this specific recall). I don't know if that's their policy, or Lexus-wide.
Its probably your dealers policy, not Lexus policy. Mine went in with approximately 1/2 tank of fuel and came out near empty.