Shabbos 2a - The Melachos Must Have Been Performed In The Mishkan

Tosfos ד"ה פשט says that since הוצאה is an "inferior melacha" [מלאכה גרועה] one is not חייב on the  תולדה of הוצאה unless it was done in the mishkan. How does the fact that the melacha was done in the mishkan fill in for the חסרון of מלאכה גרועה? Since we see that the fact that it was done in the mishkan doesn't suffice to turn it into an אב, why is it considered a תולדה?

Rav Leib Mallin was a top student in the Mir in Poland and later was Rosh Yeshiva of Beis HaTalmud in Brooklyn. He wrote two volumes called Chiddushei Rebbi Aryeh Leib which are a staple food for bnei yeshivos. In סימן ז he explains as follows: Something is only considered a melacha unless it was performed in the mishkan. A תולדה is also forbidden because it is included in the אב and it is as if he performed the אב and ממילא he did a melacha that was done in the mishkan. Now we can understand the inferiority of the melacha of הוצאה. We cannot say that when he performed the תולדה it is as if he performed the אב! Only with respect to other melachos where the Torah forbade even melachos that were similar to the אב we can say that when he did the תולדה it is as if he did the אב. But with respect to הוצאה we see that the Torah did not forbid an action that is very similar to the אב, namely carrying from רשות היחיד to רשות היחיד. Therefore, we cannot forbid a תולדה unless it was in the mishkan. Since הוצאה is a מלאכה גרועה and and is not considered as if the אב was done, it doesn't have the חשיבות of a melacha unless it was performed in the mishkan.

The point is that it has to be a a mishkan-dike מעשה - either because it is included in the אב which was done in the mishkan or it was done in the mishkan itself.

See there where he expands on this principle.