IRS Circular 230 Disclosure: Any discussion of or advice regarding United States tax
matters contained herein (including any attachments hereto) does not
meet the requirements necessary
to be a "covered opinion" as defined in Internal Revenue Service
Circular 230, and therefore, is not intended or written to be relied
upon or used and can not be relied upon or used for the purpose of
avoiding federal tax penalties that may be imposed or for
the purpose of promoting, marketing, or recommending any tax-related
matters or advice to another party.