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Pursuant to the requirements related to practice before the Internal Revenue Service, any tax advice contained in this communication (including any attachments) is not intended or written to be used and cannot be used by any taxpayer for the purpose of (i) avoiding Federal tax penalties that may be imposed on the taxpayer or (ii) promoting, marketing or recommending to another person any tax-related matter.

The standards for federal tax practice require that certain steps be taken before written advice may be relied upon by any taxpayer to avoid federal tax penalties. This communication is not intended to comply with those standards. In order for a taxpayer to rely upon written advice to avoid penalties, it must be a "formal opinion." We would be happy to discuss with you whether you might desire a "formal opinion" and the additional cost associated with such an opinion.