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Disclaimer Pertaining to IRS Circular 230 In conformity with U.S. Treasury Department Circular 230 the documents contained in this website and any tax advice contained herein is not intended to be used, and cannot be used, for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code, nor may any such tax advice be used to promote, market or recommend to any person any transaction or matter that is the subject of these documents. The intended recipients of these documents are not subject to any limitation on the disclosure of the tax treatment or tax structure of any transaction or matter that is the subject of these documents. “The opinions set forth in this website are subject to the disclaimer pertaining to IRS Circular 230 set forth herein.” Unless expressly stated otherwise on this website, (1) nothing contained in this website was intended or written to be used, can be used by any taxpayer, or may be relied upon or used by any taxpayer for the purposes of avoiding penalties that may be imposed on the taxpayer under the Internal Revenue Code of 1986, as amended; (2) any written statement contained on this website relating to any federal tax transaction or matter may not be used by any person to support the promotion or marketing or to recommend any federal tax transaction or matter; and (3) any taxpayer should seek advice based on the taxpayer’s particular circumstances from an independent tax advisor with respect to any federal tax transaction or matter contained in this website. No one, without our express written permission, may use any part of this website in promoting, marketing or recommending an arrangement relating to any federal tax matter to one or more taxpayers.